Internal Revenue Bulletin 2025-19 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2025–19
May 5, 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
Notice 2025-24, page 1429.
This notice provides relief from penalties under section
6707A(a) and 6707(a) for participants in and material advi-
sors to micro-captive reportable transactions for disclo-
sure statements required to be filed with the Office of Tax
Shelter Analysis (OTSA) under sections 6011 and 6111,
as set forth in §§ 1.6011-10(h)(2) and (3) and 1.6011-
11(h)(2) and (3), respectively. This relief applies only if the
required disclosure statements are filed with OTSA by July
31, 2025.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2025-18, page 1430.
This Revenue Procedure provides issuers of qualified mort-
gage bonds and mortgage credit certificates with (1) the
nationwide average purchase price for residences located in
the United States, and (2) the average area purchase price
safe harbors for residences located in statistical areas in
each state, the District of Columbia, Puerto Rico, the North-
ern Mariana Islands, American Samoa, the Virgin Islands, and
Guam.
EMPLOYEE PLANS
Notice 2025-21, page 1424.
This notice sets forth updates on the corporate bond
monthly yield curve, the corresponding spot segment rates
for March 2025 used under § 417(e)(3)(D), the 24-month
average segment rates applicable for April 2025, and the
30-year Treasury rates, as reflected by the application of
§ 430(h)(2)(C)(iv).
INCOME TAX
Notice 2025-20, page 1423.
This notice announces the applicable percentage under sec-
tion 613A(c)(6)(C) for marginal oil and gas properties in the
2025 calendar year. The applicable percentage is used to
determine the amount of the percentage depletion deduction
allowable under section 613A(c)(6) with respect to oil and
natural gas produced from marginal properties.
Notice 2025-23, page 1428.
Notice 2025-23 informs taxpayers and material advisors
that final regulations regarding the identification of certain
partnership related-party basis adjustment transactions as
transactions of interest will be withdrawn through the forth-
coming publication of proposed and final regulations and that
they can rely on the notice for relief from applicable penalties
for failure to file disclosure statements. In addition, Notice
2025-23 revokes Notice 2024-54, which informed taxpay-
ers of intended proposed regulations that would provide sub-
stantive technical rules to discourage basis shifting among
related partners.
Rev. Rul. 2025-10, page 1421.
Federal rates; adjusted federal rates; adjusted federal long-
term rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for May 2025.
SPECIAL ANNOUNCEMENT
Notice 2025-22, page 1427.
This notice starts the process of eliminating extraneous and
unnecessary Internal Revenue Bulletin (IRB) guidance by iden-
tifying and obsoleting nine IRB guidance documents.
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.
May 5, 2025 Bulletin No. 2025–19

Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also, Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7872.)
Rev. Rul. 2025-10
This revenue ruling provides vari-
ous prescribed rates for federal income
tax purposes for May 2025 (the current
month). Table 1 contains the short-
term, mid-term, and long-term applica-
ble federal rates (AFR) for the current
month for purposes of section 1274(d)
of the Internal Revenue Code. Table 2
contains the short-term, mid-term, and
long-term adjusted applicable federal
rates (adjusted AFR) for the current
month for purposes of section 1288(b).
Table 3 sets forth the adjusted fed-
eral long-term rate and the long-term
tax-exempt rate described in section
382(f). Table 4 contains the appropri-
ate percentages for determining the
low-income housing credit described in
section 42(b)(1) for buildings placed in
service during the current month. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized new buildings placed in service
after July 30, 2008, shall not be less
than 9%. Finally, Table 5 contains the
federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.
REV. RUL. 2025-10 TABLE 1
Applicable Federal Rates (AFR) for May 2025
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR4.05%4.01%3.99%3.98%
110% AFR4.46%4.41%4.39%4.37%
120% AFR4.87%4.81%4.78%4.76%
130% AFR5.28%5.21%5.18%5.15%
Mid-term
AFR4.10%4.06%4.04%4.03%
110% AFR 4.52%4.47%4.45%4.43%
120% AFR4.93%4.87%4.84%4.82%
130% AFR5.35%5.28%5.25%5.22%
150% AFR6.18%6.09%6.04%6.01%
175% AFR7.24%7.11%7.05%7.01%
Long-term
AFR4.62%4.57%4.54%4.53%
110% AFR5.09%5.03%5.00%4.98%
120% AFR5.56%5.48%5.44%5.42%
130% AFR6.03%5.94%5.90%5.87%
REV. RUL. 2025-10 TABLE 2
Adjusted AFR for May 2025
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR3.06%3.04%3.03%3.02%
Mid-term adjusted AFR3.10%3.08%3.07%3.06%
Long-term adjusted AFR3.50%3.47%3.46%3.45%
Bulletin No. 2025–19 1421 May 5, 2025

REV. RUL. 2025-10 TABLE 3
Rates Under Section 382 for May 2025
Adjusted federal long-term rate for the current month3.50%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)
3.64%
REV. RUL. 2025-10 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for May 2025
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit8.01%
Appropriate percentage for the 30% present value low-income housing credit 3.43%
REV. RUL. 2025-10 TABLE 5
Rate Under Section 7520 for May 2025
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
5.00%

Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of May 2025. See Rev.
Rul. 2025-10, page 1421.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of May 2025. See Rev. Rul.
2025-10, page 1421.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.
Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of May 2025. See Rev. Rul.
2025-10, page 1421.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2025. See Rev. Rul. 2025-10, page 1421.

May 5, 2025 1422 Bulletin No. 2025–19

Bulletin No. 2025–19 1423 May 5, 2025
Part III
2025 Marginal Production
Rates
Notice 2025-20
This notice announces the applicable
percentage under § 613A of the Internal
Revenue Code to be used in determining
percentage depletion for marginal proper-
ties for the 2025 calendar year.
Section 613A(c)(6)(C) defines the term
“applicable percentage” for purposes of
determining percentage depletion for oil
and gas produced from marginal prop-
erties. The applicable percentage is the
percent age (not greater than 25 percent)
equal to the sum of 15 percent, plus one
percentage point for each whole dollar
by which $20 exceeds the reference price
(determined under § 45K(d)(2)(C)) for
crude oil for the calendar year preceding
the calendar year in which the taxable year
begins. The ref erence price determined
under § 45K(d)(2)(C) for the 2024 calen-
dar year is $74.48. Accordingly, 15% is
the applicable percentage under § 613A to
be used in determining percentage deple-
tion for marginal properties for the 2025
calendar year.
The following table contains the appli-
cable percentages for marginal production
for taxable years beginning in calendar
years 1991 through 2025.
Notice 2025-20
Applicable Percentage for Marginal Production
Calendar YearApplicable Percentage
199115 percent
199218 percent
199319 percent
199420 percent
199521 percent
199620 percent
199716 percent
199817 percent
199924 percent
200019 percent
200115 percent
200215 percent
200315 percent
200415 percent
200515 percent
200615 percent
200715 percent
200815 percent
200915 percent
201015 percent
201115 percent
201215 percent
201315 percent
201415 percent
201515 percent
201615 percent
201715 percent
201815 percent
201915 percent
202015 percent
202115 percent
202215 percent
202315 percent
202415 percent
202515 percent

May 5, 2025 1424 Bulletin No. 2025–19
The principal author of this notice
is Derek Gimbel of the Office of Asso-
ciate Chief Counsel (Energy, Credits,
and Excise Tax). For further information
regarding this notice contact Derek Gim-
bel at 202-317-6853 (not a toll-free num-
ber).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2025-21
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month aver-
age segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the inter-
est rate on 30-year Treasury securities
under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to sin-
gle-employer plans (except for CSEC plans
under § 414(y)) pursuant to § 412. Section
430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under this
provision, present value is generally deter-
mined using three 24-month average inter-
est rates (“segment rates”), each of which
applies to cash flows during specified peri-
ods. To the extent provided under § 430(h)
(2)(C)(iv), these segment rates are adjusted
by the applicable percentage of the 25-year
average segment rates for the period ending
September 30 of the year preceding the cal-
endar year in which the plan year begins.
1

However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates.
Section 1.430(h)(2)-1(d) provides
rules for determining the monthly cor-
porate bond yield curve,
2
and § 1.430(h)
(2)-1(c) provides rules for determining
the 24-month average corporate bond
segment rates used to compute the tar-
get normal cost and the funding target.
Consistent with the methodology spec-
ified in § 1.430(h)(2)-1(d), the monthly
corporate bond yield curve derived from
March 2025 data is in Table 2025-3 at the
end of this notice. The spot first, second,
and third segment rates for the month of
March 2025 are, respectively, 4.50, 5.33,
and 5.86.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) to be within the appli-
cable minimum and maximum percent-
ages of the corresponding 25-year aver-
age segment rates. Those percentages are
95% and 105% for plan years beginning
in 2024 and 2025. For this purpose, any
25-year average segment rate that is less
than 5% is deemed to be 5%. The 25-year
average segment rates for plan years
beginning in 2024 and 2025 were pub-
lished in Notice 2023-66, 2023-40 I.R.B.
992 and Notice 2024-67, 2024-41 I.R.B.
726, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for April
2025 without adjustment for the 25-year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable Month First Segment Second Segment Third Segment
April 2025 4.97 5.31 5.51
The adjusted 24-month average seg-
ment rates set forth in the chart below
reflect § 430(h)(2)(C)(iv) of the Code. The
24-month averages applicable for April
2025, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates in accordance with § 430(h)(2)
(C)(iv) of the Code, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2024April 20254.975.315.59
2025April 20254.975.315.51
1
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
2
For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts
the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market.
Those enhancements are described in the preamble to TD 9986 (89 FR 2127).

Bulletin No. 2025–19 1425 May 5, 2025
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to multi-
employer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) pro-
vides that the interest rate used to calculate
current liability for this purpose must be
no more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year Trea-
sury securities during the four-year period
ending on the last day before the beginning
of the plan year. Notice 88-73, 1988-2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for March 2025 is 4.60 percent. The
Service determined this rate as the average
of the daily determinations of yield on the
30-year Treasury bond maturing in Febru-
ary 2055. For plan years beginning in April
2025, the weighted average of the rates of
interest on 30-year Treasury securities and
the permissible range of rates used to cal-
culate current liability are as follows:
Treasury Weighted Average Rates
For Plan Years Beginning In30-Year Treasury Weighted AveragePermissible Range 90% to 105%
April 20253.983.58 to 4.18
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Section 1.417(e)-1(d)(3) pro-
vides guidelines for determining the min-
imum present value segment rates. Pursu-
ant to that section, the minimum present
value segment rates determined for March
2025 are as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
March 2025 4.50 5.33 5.86
DRAFTING INFORMATION
The principal author of this notice
is Tom Morgan of the Office of Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Tony Montanaro at
626-927-1475 (not toll-free calls).

May 5, 2025 1426 Bulletin No. 2025–19
Table 2025-3
Monthly Yield Curve for March 2025
Derived from March 2025 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.54.4620.55.6940.55.8860.55.9580.55.99
1.04.4321.05.7041.05.8861.05.9581.05.99
1.54.4221.55.7141.55.8861.55.9581.55.99
2.04.4222.05.7242.05.8862.05.9582.05.99
2.54.4422.55.7242.55.8962.55.9682.55.99
3.04.4723.05.7343.05.8963.05.9683.05.99
3.54.5223.55.7443.55.8963.55.9683.55.99
4.04.5724.05.7444.05.8964.05.9684.05.99
4.54.6224.55.7544.55.9064.55.9684.55.99
5.04.6725.05.7545.05.9065.05.9685.05.99
5.54.7325.55.7645.55.9065.55.9685.56.00
6.04.7926.05.7646.05.9066.05.9686.06.00
6.54.8526.55.7746.55.9166.55.9686.56.00
7.04.9127.05.7747.05.9167.05.9787.06.00
7.54.9627.55.7847.55.9167.55.9787.56.00
8.05.0228.05.7848.05.9168.05.9788.06.00
8.55.0728.55.7848.55.9168.55.9788.56.00
9.05.1229.05.7949.05.9269.05.9789.06.00
9.55.1629.55.7949.55.9269.55.9789.56.00
10.05.2130.05.8050.05.9270.05.9790.06.00
10.55.2530.55.8050.55.9270.55.9790.56.00
11.05.2931.05.8151.05.9271.05.9791.06.00
11.55.3331.55.8151.55.9271.55.9791.56.00
12.05.3632.05.8252.05.9372.05.9892.06.00
12.55.3932.55.8252.55.9372.55.9892.56.00
13.05.4233.05.8353.05.9373.05.9893.06.00
13.55.4533.55.8353.55.9373.55.9893.56.00
14.05.4834.05.8354.05.9374.05.9894.06.01
14.55.5034.55.8454.55.9374.55.9894.56.01
15.05.5235.05.8455.05.9475.05.9895.06.01
15.55.5535.55.8555.55.9475.55.9895.56.01
16.05.5736.05.8556.05.9476.05.9896.06.01
16.55.5836.55.8556.55.9476.55.9896.56.01
17.05.6037.05.8657.05.9477.05.9897.06.01
17.55.6237.55.8657.55.9477.55.9897.56.01
18.05.6338.05.8658.05.9478.05.9998.06.01
18.55.6538.55.8758.55.9578.55.9998.56.01
19.05.6639.05.8759.05.9579.05.9999.06.01
19.55.6739.55.8759.55.9579.55.9999.56.01
20.05.6840.05.8760.05.9580.05.99100.06.01

Bulletin No. 2025–19 1427 May 5, 2025
Eliminating Unnecessary
IRS Internal Revenue
Bulletin Guidance
Notice 2025-22
This notice starts the process of elimi-
nating extraneous and unnecessary Inter-
nal Revenue Bulletin (IRB) guidance by
identifying and obsoleting nine IRB guid-
ance documents.
BACKGROUND
On February 19, 2025, the President
issued Executive Order 14219, Ensuring
Lawful Governance and Implementing
the President’s ‘Department of Govern-
ment Efficiency’ Deregulatory Initiative
(Executive Order). The purpose of the
Executive Order includes focusing the
executive branch’s limited enforcement
resources on regulations and other guid-
ance documents “squarely authorized by
constitutional Federal statutes,” elimi-
nating “overbearing and burdensome”
regulations and other guidance docu-
ments, and “ending Federal overreach.”
To further these goals, the Executive
Order directs agency heads to coordi-
nate with the Department of Government
Efficiency (DOGE) Team Leads and the
Office of Management and Budget to
identify regulations and other guidance
documents to be eliminated.
Consistent with the Executive Order,
the Department of the Treasury (Trea-
sury Department) and the Internal Rev-
enue Service (IRS), in conjunction with
DOGE, have undertaken a review of regu-
lations and IRB guidance issued under the
Internal Revenue Code (Code)
1
to identify
guidance to be eliminated. This review is
ongoing. In this notice, nine IRB guidance
documents are being obsoleted. These
guidance documents no longer provide
useful information and clarifying their
status as obsolete will streamline admin-
istration of the tax laws; reduce the vol-
ume of guidance that taxpayers and their
advisors need to review for compliance
with the tax laws; and increase clarity of
the tax law. The Treasury Department and
the IRS anticipate revoking or obsoleting
hundreds of similar guidance documents
in the near future.
GUIDANCE TO BE ELIMINATED
.01 The following document relates to
a listed transaction identified by a notice
issued under § 1.6011-4:
Notice 2015-73, Listing Notice – Bas-
ket Option Contracts, 2015-46 IRB 660
(11-16-2015). Notice 2015-73 identifies
as a listed transaction a type of structured
financial transaction in which a taxpayer
attempts to defer and treat ordinary income
and short-term capital gain (earned under
a contract denominated as an option con-
tract that references a basket of securities)
as long-term capital gain. The IRS will no
longer defend this listed transaction notice
in accordance with Action on Decision
2024-1, 2024-52 IRB 1354 (12-24-2024).
.02 The following notice applied to the
Troubled Asset Relief Program, which is
no longer operative:
Notice 2009-49, Guidance Under §
409A(a)(2)(A)(v) on Certain Transactions
Pursuant to the Emergency Economic
Stabilization Act of 2008, 2009-25 IRB
1093 (6-22-2009). This notice provides
that, if the Treasury Department acquires
preferred stock, common stock, warrants
to purchase common stock or other types
of equity of a financial institution or other
entity pursuant to the Emergency Eco-
nomic Stabilization Act of 2008, Public
Law 110-343, 122 Stat. 3765 (October
3, 2008), then such acquisition is not a
change in control event with respect to
which a payment can be made under a
nonqualified deferred compensation plan
pursuant to § 409A(a)(2)(A)(v).
.03 The following guidance relates to
repealed Code provisions:
(1) Notice 2018-10, Medical Device
Excise Tax Deposit Penalty Relief, 2018-8
IRB 359 (2-20-2018). This notice pro-
vides guidance relating to the excise tax
on medical devices imposed by § 4191
by providing temporary relief, for the first
three calendar quarters of 2018, to medi-
cal device manufacturers, producers, and
importers from the failure to deposit pen-
alties imposed by § 6656, where the tax-
payer demonstrates good faith.
(2) Announcement 2013-23, Taxable
Medical Devices; Correction, 2013-16
IRB 940 (4-15-2013). This document
republishes corrections to final regulations
(T.D. 9604, 2012-52 IRB 730) that pro-
vide guidance on the excise tax imposed
on the sale of certain medical devices.
(3) Announcement 2013-19, Taxable
Medical Devices; Correction, 2013-
14 IRB 760 (4-1-2013). This document
republishes corrections to final regulations
(T.D. 9604, 2012-52 IRB 730) that pro-
vide guidance on the excise tax imposed
on the sale of certain medical devices.
(4) Notice 2015-16, Excise Tax on
High Cost Employer-Sponsored Health
Coverage, 2015-10 IRB 732 (3-9-
2015). This notice describes potential
approaches with regard to a number of
issues under § 4980I, including the defi-
nition of applicable coverage, the deter-
mination of the cost of applicable cov-
erage, and the application of the annual
statutory dollar limit to the cost of appli-
cable coverage.
(5) Notice 2015-52, Section 4980l –
Excise Tax on High Cost Employer-Spon-
sored Health Coverage, 2015-35 IRB 227
(8-31-2015). This notice addresses addi-
tional issues under § 4980l, including the
identification of taxpayers who may be
liable for the excise tax, employer aggre-
gation, exclusion from the cost of appli-
cable coverage amounts attributable to the
excise tax, age and gender adjustment to
the dollar limit, the allocation of the tax
among applicable taxpayers, and payment
of the applicable tax.
.04 The following guidance relates to
outdated Code provisions:
Notice 2005-64, Foreign Tax Credit
and Other Guidance Under Section 965,
2005-36 IRB 471 (9-6-2005). This notice
provides guidance on the one-time div-
idends received deduction under former
§ 965 for certain cash dividends from
controlled foreign corporations that are
invested in the United States, foreign tax
credit and related issues, foreign currency
translation, the alternative minimum tax,
and the credit for prior year minimum tax.
.05 The following guidance relates to a
topic now squarely addressed by amend-
ments made to the Code by Public Law
115-97, 131 Stat. 2054 (December 22,
1
Unless otherwise specified, all “Section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

May 5, 2025 1428 Bulletin No. 2025–19
2017), commonly known as the Tax Cuts
and Jobs Act.
Rev. Rul. 91-32, Partnership Effec-
tively Connected Income Lookthrough,
199-20 IRB 20 (5-20-1991). This reve-
nue ruling addresses the United States
tax consequences of the disposition of a
foreign partner’s interest in a domestic or
foreign partnership that conducts a trade
or business through a fixed place of busi-
ness or has a permanent establishment in
the United States.
EFFECT ON OTHER DOCUMENTS
Notice 2015-73 is obsoleted.
Notice 2009-49 is obsoleted.
Notice 2018-10 is obsoleted.
Announcement 2013-23 is obsoleted.
Announcement 2013-19 is obsoleted.
Notice 2015-16 is obsoleted.
Notice 2015-52 is obsoleted.
Notice 2005-64 is obsoleted.
Rev. Rul. 91-32 is obsoleted.
DRAFTING INFORMATION
This notice was drafted by the Office
of the Associate Chief Counsel (Procedure
and Administration). For further informa-
tion, contact the Office of the Associate
Chief Counsel (Procedure and Adminis-
tration) at (202) 317-3400 (not a toll-free
number).
Notice of Intent to Remove
26 CFR 1.6011-18; Waiver
of Penalties under Sections
6707A(a), 6707(a), and
6708; Withdrawal of Notice
2024-54
Notice 2025-23
SECTION 1. PURPOSE
This notice announces that the Depart-
ment of the Treasury (Treasury Depart-
ment) and the Internal Revenue Service
(IRS) intend to publish a notice of proposed
rulemaking (forthcoming NPRM) propos-
ing to remove § 1.6011-18
1
(Basis Shifting
TOI Regulations) from the Income Tax
Regulations (26 CFR part 1). This notice
provides immediate relief from (i) pen-
alties under § 6707A(a) to participants in
transactions identified as transactions of
interest in the Basis Shifting TOI Regu-
lations that are required to file disclosure
statements under § 6011, and (ii) penalties
under §§ 6707(a) and 6708 for material
advisors to transactions identified as trans-
actions of interest in the Basis Shifting TOI
Regulations that are required to file disclo-
sure statements under § 6111 and maintain
lists under § 6112. Lastly, this notice with-
draws Notice 2024-54, 2024-28 I.R.B. 24
(Basis Shifting Notice), which describes
certain proposed regulations that the Trea-
sury Department and the IRS intended to
issue addressing partnership related-party
basis shifting transactions.
SECTION 2. BACKGROUND
On February 19, 2025, the President
issued Executive Order 14219, Ensuring
Lawful Governance and Implementing the
President’s “Department of Government
Efficiency” Deregulatory Initiative (Execu-
tive Order 14219). Executive Order 14219
directs agencies to initiate a review process
for the identification and removal of certain
regulations and other guidance that meet any
of the factors set forth in Executive Order
14219. Pursuant to the review directed
by Executive Order 14219, the Treasury
Department and the IRS have identified the
Basis Shifting TOI Regulations for removal
and the Basis Shifting Notice for withdrawal
as described in this notice.
SECTION 3. FORTHCOMING
REMOVAL OF THE BASIS
SHIFTING TOI REGULATIONS
AND RELATED APPLICABILITY
DATES
.01 Effective January 14, 2025, the Basis
Shifting TOI Regulations identify certain
partnership related-party basis adjustment
transactions and substantially similar trans-
actions as transactions of interest. Taxpay-
ers and their material advisors have criti-
cized the Basis Shifting TOI Regulations
as imposing complex, burdensome, and
retroactive disclosure obligations on many
ordinary-course and tax-compliant busi-
ness activities, creating costly compliance
obligations and uncertainty for businesses.
.02 Pursuant to Executive Order 14219,
the Treasury Department and the IRS have
identified the Basis Shifting TOI Regula-
tions as appropriate for removal and intend
to publish the forthcoming NPRM propos-
ing to remove the Basis Shifting TOI Regu-
lations from 26 CFR part 1. The forthcom-
ing NPRM, when finalized, will obviate the
need for participants and material advisors
to comply with all of the transaction of
interest requirements they would otherwise
be required to follow because of the Basis
Shifting TOI Regulations.
.03 The forthcoming NPRM will have
a proposed applicability date that corre-
sponds with the date this notice is issued
to the public. See § 7805(b)(1)(C).
.04 The forthcoming NPRM will pro-
pose that taxpayers and material advisors
may choose to apply the final regulations
retroactively to January 14, 2025, which is
the applicability date of the Basis Shifting
TOI Regulations. See § 7805(b)(7).
.05 Taxpayers and material advisors
may rely on this notice until the forthcom-
ing NPRM is finalized.
SECTION 4. WAIVER OF RELATED
DISCLOSURE STATEMENT
PENALTIES
.01 Participant penalty waiver. Given
the Treasury Department and the IRS’s
intent to propose the removal of the Basis
Shifting TOI Regulations, the IRS will, in
the interest of sound tax administration,
waive penalties under § 6707A(a) for any
failure to file a Form 8886, Reportable
Transaction Disclosure Statement, that is
otherwise required because of the Basis
Shifting TOI Regulations.
.02 Material advisor penalty waiver.
Given the Treasury Department and the
IRS’s intent to propose the removal of the
Basis Shifting TOI Regulations, the IRS
will, in the interest of sound tax admin-
istration, waive penalties under § 6707(a)
for any failure to file a Form 8918, Mate-
rial Advisor Disclosure Statement, and
also will waive penalties under § 6708 for
any failure to maintain a list under § 6112,
1
Unless otherwise specified, all “Section” or “§” references are to sections of the Internal Revenue Code or the Income Tax Regulations (26 CFR part 1).

Bulletin No. 2025–19 1429 May 5, 2025
that is otherwise required because of the
Basis Shifting TOI Regulations.
SECTION 5. WITHDRAWAL OF THE
BASIS SHIFTING NOTICE
The Basis Shifting Notice announced
the Treasury Department and the IRS’s
intention to publish certain proposed regu-
lations addressing partnership related-party
basis shifting transactions. Stakeholders
have stated that the intended proposed
regulations, if finalized, would impose
complex, burdensome, and retroactive
technical rules on many ordinary-course
and tax-compliant business activities, cre-
ating costly compliance obligations and
uncertainty for businesses. After the review
directed by Executive Order 14219, the
Basis Shifting Notice is hereby withdrawn.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Notice 2024-54 is withdrawn.
SECTION 7. DRAFTING
INFORMATION
The principal authors of this notice are
Anthony Sacco, Jeremy Milton, and Eliz-
abeth Zanet of the Office of the Associate
Chief Counsel (Passthroughs, Trusts, and
Estates). For further information regard-
ing this notice contact Mr. Sacco, Mr. Mil-
ton, or Ms. Zanet at (202) 317-5279 (not a
toll-free number).
Limited Waiver of Penalties
for Certain Disclosure
Statements for Micro-
captive Reportable
Transactions
Notice 2025-24
SECTION 1. PURPOSE
This notice provides relief from penal-
ties under section 6707A(a) of the Internal
Revenue Code (Code)
1
to participants in
micro-captive reportable transactions that
fail to file certain disclosure statements
required under section 6011 and § 1.6011-
10(h)(2) or § 1.6011-11(h)(2) by April
14, 2025. This relief applies only if such
participants file the required disclosure
statement with the Office of Tax Shelter
Analysis (OTSA) by July 31, 2025. In
addition, this notice provides relief from
penalties under section 6707(a) for mate-
rial advisors to certain micro-captive
reportable transactions that are required
under section 6111 and § 1.6011-10(h)(3)
or § 1.6011-11(h)(3) to file a disclosure
statement with OTSA by April 30, 2025, if
such material advisors file the disclosure
statement with OTSA by July 31, 2025.
The relevant penalties will be waived as
described in section 3 of this notice.
SECTION 2. BACKGROUND
On January 14, 2025, the Department
of the Treasury (Treasury Department)
and the Internal Revenue Service (IRS)
published final regulations under section
6011 (§§ 1.6011-10 and 1.6011-11) in the
Federal Register (TD 10029, 90 FR 3559,
90 FR 3562). Section 1.6011-10(a) iden-
tifies transactions that are the same as, or
substantially similar to, certain micro-cap-
tive transactions as listed transactions, a
type of reportable transaction (Micro-cap-
tive Listed Transaction). Section 1.6011-
11(a) identifies transactions that are the
same as, or substantially similar to, cer-
tain other micro-captive transactions as
transactions of interest, another type of
reportable transaction (Micro-captive
Transaction of Interest). Material advisors
and certain participants in these reportable
transactions are required to file disclosure
statements with the IRS and OTSA and are
subject to penalties if they fail to timely
make such disclosures. In describing the
disclosure obligations for participants and
material advisors, respectively, §§ 1.6011-
10 and 1.6011-11 reference the provisions
of § 1.6011-4(e), for participants, and
§ 301.6111-3, for material advisors.
Generally, § 1.6011-4(e)(1) provides
that the disclosure statement for a report-
able transaction must be attached to the
taxpayer’s tax return for each taxable
year for which a taxpayer participates in
a reportable transaction. In addition, a dis-
closure statement for a reportable trans-
action must be attached to each amended
return that reflects a taxpayer’s participa-
tion in a reportable transaction. A copy of
the disclosure statement must be sent to
OTSA at the same time that any disclo-
sure statement is first filed by the taxpayer
pertaining to a particular reportable trans-
action.
In addition, § 1.6011-4(e)(2)(i) pro-
vides that if a transaction becomes a listed
transaction or a transaction of interest
after the filing of a taxpayer’s tax return
(including an amended return) reflecting
the taxpayer’s participation in the transac-
tion and before the end of the period of
limitations for assessment of tax for any
taxable year in which the taxpayer par-
ticipated in the transaction, then a disclo-
sure statement must be filed, regardless
of whether the taxpayer participated in
the transaction in the year the transaction
became a listed transaction or a transac-
tion of interest, with OTSA within 90
calendar days after the date on which the
transaction became a listed transaction or
a transaction of interest (Participant Later
Identified Transaction rule). Participants
required to disclose these transactions
pursuant to section 6011 and § 1.6011-4
who fail to do so may be subject to a pen-
alty under section 6707A(a).
Section 301.6111-3(e) provides that a
material advisor’s disclosure statement
for a reportable transaction must be filed
with OTSA by the last day of the month
that follows the end of the calendar quar-
ter in which the advisor became a mate-
rial advisor with respect to the reportable
transaction or in which the circumstances
necessitating an amended disclosure
statement occur. Section 301.6111-3(b)
(4)(iii) provides that if a transaction that
was not a reportable transaction is iden-
tified as a listed transaction or a transac-
tion of interest in published guidance after
the occurrence of the events described in
§ 301.6111-3(b)(4)(i), the person will be
treated as becoming a material advisor
on the date the transaction is identified
as a listed transaction or a transaction of
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code, the Income Tax Regulations (26 CFR part 1), or the Procedure and Administration Regulations (26
CFR part 301).

May 5, 2025 1430 Bulletin No. 2025–19
interest (Material Advisor Later Identi-
fied Transaction rule). Material advisors
required to disclose these transactions
pursuant to section 6111 and § 301.6111-3
who fail to do so may be subject to a pen-
alty under section 6707(a).
Sections 1.6011-10(a) and 1.6011-
11(a) identified certain micro-captive
transactions as Micro-captive Listed
Transactions or Micro-captive Transac-
tions of Interest effective as of January
14, 2025. Consequently, as described in
§§ 1.6011-10(h)(2) and 1.6011-11(h)(2),
participants in transactions identified in
§§ 1.6011-10(a) and 1.6011-11(a) who
filed returns reflecting their participation
in such transactions and for which the
period of limitations for assessment of tax
had not ended on or before January 14,
2025, generally must file initial disclo-
sure statements with OTSA by April 14,
2025, as required by the Participant Later
Identified Transaction rule. The Partici-
pant Later Identified Transaction rule may
not apply for taxpayers who have final-
ized a settlement agreement, as set forth
in §§ 1.6011-10(h)(2) and 1.6011-11(h)
(2). Further, the Participant Later Iden-
tified Transaction rule may not apply for
participants in Micro-captive Transactions
of Interest that filed disclosure statements
pursuant to Notice 2016-66, 2016-47
I.R.B. 745, as set forth in § 1.6011-11(h)
(2). As described in §§ 1.6011-10(h)(3)
and 1.6011-11(h)(3), material advisors to
transactions identified in §§ 1.6011-10(a)
and 1.6011-11(a) who made a tax state-
ment on or after January 14, 2019, must
file the required disclosure with OTSA by
April 30, 2025, as required by the Mate-
rial Advisor Later Identified Transaction
rule. Transactions for which the Partici-
pant Later Identified Transaction rule or
Material Advisor Later Identified Trans-
action rule apply are referred to as “Later
Identified Micro-captive Listed Transac-
tions” and “Later Identified Micro-captive
Transactions of Interest.”
Stakeholders have raised concerns
regarding the ability of micro-captive
reportable transaction participants to
timely comply with their initial filing
obligations with respect to Later Identi-
fied Micro-captive Listed Transactions
and Later Identified Micro-captive Trans-
actions of Interest. As further described
in section 3 of this notice, the Treasury
Department and the IRS are providing a
limited waiver of penalties under sections
6707A(a) and 6707(a).
SECTION 3. LIMITED WAIVER OF
PENALTIES
.01 Participant penalty waiver. In light
of potential challenges associated with
preparing disclosure statements during
tax return filing season and in the interest
of sound tax administration, the IRS will
waive penalties under section 6707A(a)
with respect to Later Identified Micro-cap-
tive Listed Transaction and Later Identi-
fied Micro-captive Transaction of Inter-
est disclosure statements completed in
accordance with § 1.6011-4(d) and the
Instructions to Form 8886, Reportable
Transaction Disclosure Statement, if the
participant files the required disclosure
statement with OTSA by July 31, 2025.
This relief is limited to Later Identi-
fied Micro-captive Listed Transactions
and Later Identified Micro-captive Trans-
actions of Interest. This notice does not
provide relief from penalties under sec-
tion 6707A(a) for participants required to
file a copy of their disclosure statements
with OTSA at the same time the partici-
pant first files a disclosure statement by
attaching it to the participant’s tax return
pursuant to § 1.6011-4(e)(1). Taxpayers
concerned about meeting the due date for
such disclosure statements can request
an extension of the due date for their tax
return to obtain additional time to file
such disclosure statements. Disclosures
required from participants with respect
to Micro-captive Listed Transactions and
Micro-captive Transactions of Interest on
or after July 31, 2025, remain due as oth-
erwise set forth in § 1.6011-4(e).
.02 Material advisor penalty waiver.
In light of potential challenges associ-
ated with preparing disclosure statements
during tax return filing season and in
the interest of sound tax administration,
the IRS will waive penalties under sec-
tion 6707(a) with respect to Later Identi-
fied Micro-captive Listed Transaction and
Later Identified Micro-captive Transac-
tion of Interest disclosure statements com-
pleted in accordance with § 301.6111-3(d)
and the instructions to Form 8918, Mate-
rial Advisor Disclosure Statement, if the
material advisor files the required disclo-
sure statement with OTSA by July 31,
2025.
Disclosures required from material
advisors with respect to Micro-captive
Listed Transactions and Micro-captive
Transactions of Interest on or after July
31, 2025, remain due as otherwise set
forth in § 301.6111-3(e). This notice
does not modify any list maintenance
and furnishment obligations of material
advisors as set forth in section 6112 and
§ 301.6112-1.
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is
Allan H. Sakaue of the Office of Associate
Chief Counsel (Financial Institutions &
Products). For further information regard-
ing this notice contact Mr. Sakaue at (202)
317-6995 (not a toll-free number).
26 CFR 601.601: Rules and Regulations
(Also: Part 1, §§ 25, 143, 6a.103A-1(b)(4),
6a.103A-2(f)(5).)
Rev. Proc. 2025-18
SECTION 1. PURPOSE
This revenue procedure provides
issuers of qualified mortgage bonds, as
defined in § 143(a) of the Internal Reve-
nue Code
1
, and issuers of mortgage credit
certificates, as defined in § 25(c), with (1)
the nationwide average purchase price for
residences located in the United States,
and (2) average area purchase price safe
harbors for residences located in statis-
tical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that,
except as provided in § 103(b), gross
1
Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code or the Temporary Regulations under Title II of the Omnibus Reconciliation Act of
1980 (26 CFR part 6a).

Bulletin No. 2025–19 1431 May 5, 2025
income does not include interest on any
State or local bond. Section 103(b)(1) pro-
vides that § 103(a) shall not apply to any
private activity bond that is not a “quali-
fied bond” within the meaning of § 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activity bond if such bond (1) is a quali-
fied mortgage bond under § 143, (2) meets
the volume cap requirements under § 146,
and (3) meets the applicable requirements
under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A) pro-
vides that the term “qualified mortgage
issue” means an issue of one or more
bonds by a State or political subdivi-
sion thereof, but only if: (i) all proceeds
of the issue (exclusive of issuance costs
and a reasonably required reserve) are to
be used to finance owner-occupied res-
idences; (ii) the issue meets the require-
ments of subsections (c), (d), (e), (f), (g),
(h), (i), and (m)(7) of § 143; (iii) the issue
does not meet the private business tests
of paragraphs (1) and (2) of § 141(b);
and (iv) with respect to amounts received
more than 10 years after the date of issu-
ance, repayments of $250,000 or more of
principal on mortgage financing provided
by the issue are used by the close of the
first semiannual period beginning after the
date the prepayment (or complete repay-
ment) is received to redeem bonds that are
part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of § 143(e) if the acquisi-
tion cost of each residence financed by
the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro-
vides that, in the case of a targeted area
residence (as defined in § 143(j)), § 143(e)
(1) shall be applied by substituting 110
percent for 90 percent.
.04 Section 143(e)(2) provides that the
term “average area purchase price” means,
with respect to any residence, the average
purchase price of single-family residences
(in the statistical area in which the res-
idence is located) that were purchased
during the most recent 12-month period
for which sufficient statistical informa-
tion is available. Under §§ 143(e)(3) and
(4), respectively, separate determinations
of average area purchase price are to be
made for new and existing residences,
and for two-, three-, and four-family res-
idences.
.05 Section 143(e)(2) also provides that
the determination of the average area pur-
chase price shall be made as of the date
on which the commitment to provide the
financing is made or, if earlier, the date of
the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a met-
ropolitan statistical area (MSA), and (ii)
any county (or the portion thereof) that is
not within an MSA. Section 143(k)(2)(C)
further provides that if sufficient recent
statistical information with respect to a
county (or portion thereof) is unavailable,
the Secretary may substitute another area
for which there is sufficient recent statis-
tical information for such county (or por-
tion thereof). In the case of any portion
of a State which is not within a county,
§ 143(k)(2)(D) provides that the Secretary
may designate an area that is the equiva-
lent of a county. Section 6a.103A-1(b)(4)
(i) (issued under § 103A of the Internal
Revenue Code of 1954, the predecessor
of § 143) provides that the term “State”
includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A-2(f)(5)(i) provides
that an issuer may rely upon the average
area purchase price safe harbors published
by the Department of the Treasury (Trea-
sury Department) for the statistical area
in which a residence is located. Section
6a.103A-2(f)(5)(i) further provides that
an issuer may use an average area pur-
chase price limitation different from the
published safe harbor if the issuer has
more accurate and comprehensive data for
the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a State or
political subdivision thereof to establish
a qualified mortgage credit certificate
program. In general, a qualified mortgage
credit certificate program is a program
under which the issuing authority elects
not to issue an amount of private activity
bonds that it may otherwise issue during
the calendar year under § 146, and in its
place, issues mortgage credit certificates
to taxpayers in connection with the acqui-
sition of their principal residences. Sec-
tion 25(a)(1) provides, in general, that the
holder of a mortgage credit certificate may
claim a federal income tax credit equal to
the product of the credit rate specified
in the certificate and the interest paid or
accrued during the tax year on the remain-
ing principal of the indebtedness incurred
to acquire the residence. Section 25(c)(2)
(A)(iii)(III) generally provides that res-
idences acquired in connection with the
issuance of mortgage credit certificates
must meet the purchase price require-
ments of § 143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, § 25(c)
(2)(A)(iii)(IV) provides that holders of
mortgage credit certificates must meet
the income requirement of § 143(f).
Generally, under §§ 143(f)(1) and 25(c)
(2)(A)(iii)(IV), the income requirement
is met only if all owner-financing under
a qualified mortgage bond and all mort-
gage credit certificates issued under a
qualified mortgage credit certificate pro-
gram are provided to mortgagors whose
family income is 115 percent or less of
the applicable median family income.
Section 143(f)(5), however, generally
provides for an upward adjustment to
the percentage limitation in high hous-
ing cost areas. High housing cost areas
are defined in § 143(f)(5)(C) as any sta-
tistical area for which the housing cost/
income ratio is greater than 1.2.
.10 Under § 143(f)(5)(D), the hous-
ing cost/income ratio with respect to any
statistical area is determined by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area
median gross income for such area bears
to the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new hous-
ing average area purchase price divided

May 5, 2025 1432 Bulletin No. 2025–19
by the new housing average purchase
price for the United States) or the exist-
ing housing price ratio (existing housing
average area purchase price divided by the
existing housing average purchase price
for the United States), whichever results
in the housing cost/income ratio being
closer to 1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2024-21, 2024-19 I.R.B. 1054.
.12 The nationwide average purchase
price was last published in section 4.02 of
Rev. Proc. 2024-21. Guidance with respect
to the United States and area median gross
income figures that are used in computing
the housing cost/income ratio described in
§ 143(f)(5) was published in Rev. Proc.
2021-19, 2021-15 I.R.B. 1008.
.13 This revenue procedure uses Fed-
eral Housing Administration (FHA) loan
limits for a given statistical area to calcu-
late the average area purchase price safe
harbor for that area. FHA sets limits on the
dollar value of loans it will insure based on
median home prices and conforming loan
limits established by the Federal Home
Loan Mortgage Corporation. In particular,
FHA sets an area’s loan limit at 95 per-
cent of the median home sales price for
the area, subject to certain floors and caps
measured against conforming loan limits.
.14 To calculate the average area pur-
chase price safe harbors in this reve-
nue procedure, the FHA loan limits are
adjusted to take into account the differ-
ences between average and median pur-
chase prices. Because FHA loan limits do
not differentiate between new and existing
residences, this revenue procedure con-
tains a single average area purchase price
safe harbor for both new and existing res-
idences in a statistical area.
.15 The average area purchase price
safe harbors listed in section 4.01 of this
revenue procedure are based on FHA
loan limits released November 26, 2024.
FHA loan limits are available for statis-
tical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam. See section 3.03 of
this revenue procedure with respect to
FHA loan limits revised after November
26, 2024.
.16 OMB Bulletin No. 03-04, dated
and effective June 6, 2003, revised the
definitions of the nation’s metropolitan
areas and recognized 49 new MSAs. The
OMB bulletin no longer includes primary
MSAs.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single-fam-
ily and two to four-family residences. For
each type of residence, section 4.01 of this
revenue procedure contains a single safe
harbor that may be used for both new and
existing residences. Issuers of qualified
mortgage bonds and issuers of mortgage
credit certificates may rely on these safe
harbors to satisfy the requirements of §§
143(e) and (f). Section 4.01 of this reve-
nue procedure provides safe harbors for
MSAs and for certain counties and county
equivalents. If no purchase price safe har-
bor is available for a statistical area, the
safe harbor for “ALL OTHER AREAS”
may be used for that statistical area.
.02 If a residence is in an MSA, the safe
harbor applicable to it is the limitation of
that MSA. If an MSA falls in more than
one state, the MSA is listed in section 4.01
of this revenue procedure under each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Novem-
ber 26, 2024, an issuer of qualified mort-
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for that
statistical area to compute (as provided in
the next sentence) a revised average area
purchase price safe harbor for the statisti-
cal area provided that the issuer maintains
records evidencing the revised FHA loan
limit. The revised average area purchase
price safe harbor for that statistical area
is computed by dividing the revised FHA
loan limit by 0.867.
.04 If, pursuant to § 6a.103A-2(f)(5)(i),
an issuer uses more accurate and compre-
hensive data to determine the average area
purchase price for a statistical area, the
issuer must make separate average area
purchase price determinations for new
and existing residences. Moreover, when
computing the average area purchase
price for a statistical area that is an MSA,
as defined in OMB Bulletin No. 23-01, the
issuer must make the computation for the
entire applicable MSA. When computing
the average area purchase price for a sta-
tistical area that is not an MSA, the issuer
must make the computation for the entire
statistical area and may not combine sta-
tistical areas. Thus, for example, the issuer
may not combine two or more counties.
.05 If an issuer receives a ruling per-
mitting it to rely on an average area pur-
chase price limitation that is higher than
the applicable safe harbor in this revenue
procedure, the issuer may rely on that
higher limitation for the purpose of satis-
fying the requirements of §§ 143(e) and
(f) for bonds sold, and mortgage credit
certificates issued, not more than 30
months following the termination date of
the 12-month period used by the issuer to
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue pro-
cedure sets forth a single nationwide
average purchase price for purposes of
computing the housing cost/income ratio
under § 143(f)(5).
.07 Issuers must use the nationwide
average purchase price set forth in sec-
tion 4.02 of this revenue procedure when
computing the housing cost/income ratio
under § 143(f)(5) regardless of whether
they are relying on the average area pur-
chase price safe harbors contained in this
revenue procedure or using more accu-
rate and comprehensive data to determine
average area purchase prices for new and
existing residences for a statistical area
that are different from the published safe
harbors in this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2024-21, the issuer

Bulletin No. 2025–19 1433 May 5, 2025
must use the nationwide average purchase
price set forth in section 4.02 of Rev. Proc.
2024-21 in computing the housing cost/
income ratio under § 143(f)(5). Likewise,
if, pursuant to section 6.04 of this revenue
procedure, an issuer relies on the nation-
wide average purchase price published in
Rev. Proc. 2024-21, the issuer must use
the average area purchase price safe har-
bors set forth in section 4.01 of Rev. Proc.
2024-21 in computing the housing cost/
income ratio under § 143(f)(5).
SECTION 4. AVERAGE AREA
AND NATIONWIDE AVERAGE
PURCHASE PRICES
.01 Average area purchase prices for
single-family and two to four-family res-
idences in MSAs, and for certain coun-
ties and county equivalents are set forth
below. The safe harbor for “ALL OTHER
AREAS” (found at the end of the table
below) may be used for a statistical area
that is not listed below.
2025 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
ALEUTIANS WESTAK675,212864,3891,044,8571,298,515
HOONAH-ANGOON CAK604,905774,357936,0221,163,265
JUNEAU CITY ANDAK638,068816,864987,3541,227,055
KODIAK ISLAND BAK624,803799,849966,8211,201,562
SITKA CITY ANDAK676,538866,0611,046,8751,301,053
SKAGWAY MUNICIPAK604,905774,357936,0221,163,265
COCONINOAZ650,007832,1481,005,8681,250,010
MARICOPAAZ630,109806,655975,0691,211,771
PINALAZ630,109806,655975,0691,211,771
ALAMEDACA1,395,4681,786,7712,159,6452,684,092
CONTRA COSTACA1,395,4681,786,7712,159,6452,684,092
EL DORADOCA880,8261,127,6221,363,0551,693,941
LOS ANGELESCA1,395,4681,786,7712,159,6452,684,092
MARINCA1,395,4681,786,7712,159,6452,684,092
MENDOCINOCA630,109806,655975,0691,211,771
MONOCA895,4181,146,3091,385,6061,721,972
MONTEREYCA1,119,6051,433,3041,732,5262,153,157
NAPACA1,173,9931,502,9191,816,6752,257,723
NEVADACA742,866951,0181,149,5381,428,632
ORANGECA1,395,4681,786,7712,159,6452,684,092
PLACERCA880,8261,127,6221,363,0551,693,941
RIVERSIDECA776,029993,4671,200,8701,492,364
SACRAMENTOCA880,8261,127,6221,363,0551,693,941
SAN BENITOCA1,395,4681,786,7712,159,6452,684,092
SAN BERNARDINOCA776,029993,4671,200,8701,492,364
SAN DIEGOCA1,242,9731,591,2201,923,4342,390,378
SAN FRANCISCOCA1,395,4681,786,7712,159,6452,684,092
SAN JOAQUINCA782,6621,001,9461,211,1361,505,168
SAN LUIS OBISPOCA1,115,6251,428,2281,726,3552,145,486
SAN MATEOCA1,395,4681,786,7712,159,6452,684,092
SANTA BARBARACA1,053,2771,348,4051,629,9212,025,578
SANTA CLARACA1,395,4681,786,7712,159,6452,684,092
SANTA CRUZCA1,395,4681,786,7712,159,6452,684,092

May 5, 2025 1434 Bulletin No. 2025–19
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
SOLANOCA790,6211,012,1541,223,4211,520,452
SONOMACA1,034,7061,324,6421,601,1411,989,876
STANISLAUSCA618,170791,371956,5551,188,816
VENTURACA1,173,9931,502,9191,816,6752,257,723
YOLOCA880,8261,127,6221,363,0551,693,941
ADAMSCO961,7461,231,2071,488,2691,849,551
ARAPAHOECO961,7461,231,2071,488,2691,849,551
BOULDERCO994,9091,273,6571,539,6001,913,340
BROOMFIELDCO961,7461,231,2071,488,2691,849,551
CHAFFEECO769,396984,9891,190,6041,479,618
CLEAR CREEKCO961,7461,231,2071,488,2691,849,551
DENVERCO961,7461,231,2071,488,2691,849,551
DOUGLASCO961,7461,231,2071,488,2691,849,551
EAGLECO1,395,4681,786,7712,159,6452,684,092
EL PASOCO615,517787,968952,4601,183,682
ELBERTCO961,7461,231,2071,488,2691,849,551
GARFIELDCO1,395,4681,786,7712,159,6452,684,092
GILPINCO961,7461,231,2071,488,2691,849,551
GRANDCO1,008,1751,290,6711,560,0751,938,833
GUNNISONCO862,2551,103,8591,334,2741,658,182
JEFFERSONCO961,7461,231,2071,488,2691,849,551
LA PLATACO795,9271,018,9021,231,6691,530,661
LARIMERCO729,600934,0041,129,0061,403,082
MONTROSECO866,2341,108,9351,340,4461,665,853
OURAYCO866,2341,108,9351,340,4461,665,853
PARKCO961,7461,231,2071,488,2691,849,551
PITKINCO1,395,4681,786,7712,159,6452,684,092
ROUTTCO1,167,3601,494,4401,806,4672,244,977
SAN MIGUELCO1,205,8301,543,6951,865,9882,318,975
SUMMITCO1,231,0341,575,9361,904,9772,367,423
TELLERCO615,517787,968952,4601,183,682
WELDCO650,007832,1481,005,8681,250,010
FAIRFIELDCT981,6441,256,7001,519,0681,887,790
DISTRICT OF COLDC1,395,4681,786,7712,159,6452,684,092
NEW CASTLEDE685,824878,0001,061,2941,318,932
BAKERFL669,906857,5831,036,6671,288,307
BROWARDFL754,804966,3021,167,9951,451,587
CLAYFL669,906857,5831,036,6671,288,307
COLLIERFL882,1531,129,2941,365,0731,696,479
DUVALFL669,906857,5831,036,6671,288,307
MANATEEFL631,436808,328977,0871,214,308
MARTINFL688,477881,3451,065,3891,324,008
MIAMI-DADEFL754,804966,3021,167,9951,451,587

Bulletin No. 2025–19 1435 May 5, 2025
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
MONROEFL1,115,6251,428,2281,726,3552,145,486
NASSAUFL669,906857,5831,036,6671,288,307
OKALOOSAFL696,436891,5541,077,6741,339,292
PALM BEACHFL754,804966,3021,167,9951,451,587
SARASOTAFL631,436808,328977,0871,214,308
ST. JOHNSFL669,906857,5831,036,6671,288,307
ST. LUCIEFL688,477881,3451,065,3891,324,008
WALTONFL696,436891,5541,077,6741,339,292
BARROWGA794,6011,017,2301,229,5931,528,123
BARTOWGA794,6011,017,2301,229,5931,528,123
BUTTSGA794,6011,017,2301,229,5931,528,123
CARROLLGA794,6011,017,2301,229,5931,528,123
CHEROKEEGA794,6011,017,2301,229,5931,528,123
CLARKEGA696,436891,5541,077,6741,339,292
CLAYTONGA794,6011,017,2301,229,5931,528,123
COBBGA794,6011,017,2301,229,5931,528,123
COWETAGA794,6011,017,2301,229,5931,528,123
DAWSONGA794,6011,017,2301,229,5931,528,123
DEKALBGA794,6011,017,2301,229,5931,528,123
DOUGLASGA794,6011,017,2301,229,5931,528,123
FAYETTEGA794,6011,017,2301,229,5931,528,123
FORSYTHGA794,6011,017,2301,229,5931,528,123
FULTONGA794,6011,017,2301,229,5931,528,123
GREENEGA640,722820,209991,4491,232,188
GWINNETTGA794,6011,017,2301,229,5931,528,123
HARALSONGA794,6011,017,2301,229,5931,528,123
HEARDGA794,6011,017,2301,229,5931,528,123
HENRYGA794,6011,017,2301,229,5931,528,123
JASPERGA794,6011,017,2301,229,5931,528,123
LAMARGA794,6011,017,2301,229,5931,528,123
MADISONGA696,436891,5541,077,6741,339,292
MERIWETHERGA794,6011,017,2301,229,5931,528,123
MORGANGA794,6011,017,2301,229,5931,528,123
NEWTONGA794,6011,017,2301,229,5931,528,123
OCONEEGA696,436891,5541,077,6741,339,292
OGLETHORPEGA696,436891,5541,077,6741,339,292
PAULDINGGA794,6011,017,2301,229,5931,528,123
PICKENSGA794,6011,017,2301,229,5931,528,123
PIKEGA794,6011,017,2301,229,5931,528,123
ROCKDALEGA794,6011,017,2301,229,5931,528,123
SPALDINGGA794,6011,017,2301,229,5931,528,123
WALTONGA794,6011,017,2301,229,5931,528,123
GUAMGU650,007832,1481,005,8681,250,010

May 5, 2025 1436 Bulletin No. 2025–19
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
HAWAIIHI659,293844,0291,020,2291,267,889
HONOLULUHI899,3981,151,3841,391,7771,729,643
KALAWAOHI1,268,1781,623,5191,962,4802,438,883
KAUAIHI1,281,4431,640,4761,982,9552,464,376
MAUIHI1,268,1781,623,5191,962,4802,438,883
ADAID676,538866,0611,046,8751,301,053
BLAINEID875,5201,120,8161,354,8071,683,733
BOISEID676,538866,0611,046,8751,301,053
CAMASID875,5201,120,8161,354,8071,683,733
CANYONID676,538866,0611,046,8751,301,053
GEMID676,538866,0611,046,8751,301,053
KOOTENAIID660,620845,7021,022,2481,270,427
OWYHEEID676,538866,0611,046,8751,301,053
TETONID1,395,4681,786,7712,159,6452,684,092
VALLEYID661,946847,4321,024,3241,272,965
BARNSTABLEMA921,9491,180,2801,426,6711,773,015
BRISTOLMA848,9891,086,8451,313,7421,632,689
DUKESMA1,395,4681,786,7712,159,6452,684,092
ESSEXMA1,054,6041,350,0771,631,9402,028,115
MIDDLESEXMA1,054,6041,350,0771,631,9402,028,115
NANTUCKETMA1,395,4681,786,7712,159,6452,684,092
NORFOLKMA1,054,6041,350,0771,631,9402,028,115
PLYMOUTHMA1,054,6041,350,0771,631,9402,028,115
SUFFOLKMA1,054,6041,350,0771,631,9402,028,115
ANNE ARUNDELMD843,6831,080,0391,305,5521,622,481
BALTIMOREMD843,6831,080,0391,305,5521,622,481
BALTIMORE CITYMD843,6831,080,0391,305,5521,622,481
CALVERTMD1,395,4681,786,7712,159,6452,684,092
CARROLLMD843,6831,080,0391,305,5521,622,481
CECILMD685,824878,0001,061,2941,318,932
CHARLESMD1,395,4681,786,7712,159,6452,684,092
FREDERICKMD1,395,4681,786,7712,159,6452,684,092
HARFORDMD843,6831,080,0391,305,5521,622,481
HOWARDMD843,6831,080,0391,305,5521,622,481
MONTGOMERYMD1,395,4681,786,7712,159,6452,684,092
PRINCE GEORGE'SMD1,395,4681,786,7712,159,6452,684,092
QUEEN ANNE'SMD843,6831,080,0391,305,5521,622,481
CUMBERLANDME692,457886,4791,071,5611,331,679
SAGADAHOCME692,457886,4791,071,5611,331,679
YORKME692,457886,4791,071,5611,331,679
ANOKAMN610,211781,162944,2701,173,474
CARVERMN610,211781,162944,2701,173,474
CHISAGOMN610,211781,162944,2701,173,474

Bulletin No. 2025–19 1437 May 5, 2025
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
DAKOTAMN610,211781,162944,2701,173,474
HENNEPINMN610,211781,162944,2701,173,474
ISANTIMN610,211781,162944,2701,173,474
LE SUEURMN610,211781,162944,2701,173,474
MILLE LACSMN610,211781,162944,2701,173,474
RAMSEYMN610,211781,162944,2701,173,474
SCOTTMN610,211781,162944,2701,173,474
SHERBURNEMN610,211781,162944,2701,173,474
WASHINGTONMN610,211781,162944,2701,173,474
WRIGHTMN610,211781,162944,2701,173,474
NORTHERN ISLANDMP604,905774,357936,0221,163,265
SAIPANMP610,211781,162944,2701,173,474
TINIANMP614,191786,296950,4411,181,145
CARBONMT870,2141,114,0101,346,6171,673,524
FLATHEADMT660,620845,7021,022,2481,270,427
GALLATINMT829,0911,061,4101,283,0001,594,450
MISSOULAMT646,028827,015999,6961,242,397
PARKMT650,007832,1481,005,8681,250,010
STILLWATERMT870,2141,114,0101,346,6171,673,524
YELLOWSTONEMT870,2141,114,0101,346,6171,673,524
CAMDENNC874,1941,119,1431,352,7881,681,195
CHATHAMNC729,600934,0041,129,0061,403,082
CURRITUCKNC874,1941,119,1431,352,7881,681,195
DARENC765,417979,8561,184,4321,472,004
DURHAMNC729,600934,0041,129,0061,403,082
FRANKLINNC611,538782,893946,2881,176,069
GATESNC874,1941,119,1431,352,7881,681,195
GRANVILLENC729,600934,0041,129,0061,403,082
JOHNSTONNC611,538782,893946,2881,176,069
ORANGENC729,600934,0041,129,0061,403,082
PASQUOTANKNC928,5821,188,7581,436,9371,785,761
PERQUIMANSNC928,5821,188,7581,436,9371,785,761
PERSONNC729,600934,0041,129,0061,403,082
WAKENC611,538782,893946,2881,176,069
DAWSONNE696,436891,5541,077,6741,339,292
GOSPERNE696,436891,5541,077,6741,339,292
HILLSBOROUGHNH630,109806,655975,0691,211,771
ROCKINGHAMNH1,054,6041,350,0771,631,9402,028,115
STRAFFORDNH1,054,6041,350,0771,631,9402,028,115
BERGENNJ1,395,4681,786,7712,159,6452,684,092
BURLINGTONNJ685,824878,0001,061,2941,318,932
CAMDENNJ685,824878,0001,061,2941,318,932
CAPE MAYNJ769,396984,9891,190,6041,479,618

May 5, 2025 1438 Bulletin No. 2025–19
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
ESSEXNJ1,395,4681,786,7712,159,6452,684,092
GLOUCESTERNJ685,824878,0001,061,2941,318,932
HUDSONNJ1,395,4681,786,7712,159,6452,684,092
HUNTERDONNJ1,395,4681,786,7712,159,6452,684,092
MIDDLESEXNJ1,395,4681,786,7712,159,6452,684,092
MONMOUTHNJ1,395,4681,786,7712,159,6452,684,092
MORRISNJ1,395,4681,786,7712,159,6452,684,092
OCEANNJ1,395,4681,786,7712,159,6452,684,092
PASSAICNJ1,395,4681,786,7712,159,6452,684,092
SALEMNJ685,824878,0001,061,2941,318,932
SOMERSETNJ1,395,4681,786,7712,159,6452,684,092
SUSSEXNJ1,395,4681,786,7712,159,6452,684,092
UNIONNJ1,395,4681,786,7712,159,6452,684,092
LOS ALAMOSNM798,5811,022,3051,235,7641,535,736
SANTA FENM624,803799,849966,8211,201,562
CARSON CITYNV663,273849,1051,026,4001,275,560
DOUGLASNV829,0911,061,4101,283,0001,594,450
STOREYNV729,600934,0041,129,0061,403,082
WASHOENV729,600934,0041,129,0061,403,082
BRONXNY1,395,4681,786,7712,159,6452,684,092
KINGSNY1,395,4681,786,7712,159,6452,684,092
NASSAUNY1,395,4681,786,7712,159,6452,684,092
NEW YORKNY1,395,4681,786,7712,159,6452,684,092
PUTNAMNY1,395,4681,786,7712,159,6452,684,092
QUEENSNY1,395,4681,786,7712,159,6452,684,092
RICHMONDNY1,395,4681,786,7712,159,6452,684,092
ROCKLANDNY1,395,4681,786,7712,159,6452,684,092
SUFFOLKNY1,395,4681,786,7712,159,6452,684,092
WESTCHESTERNY1,395,4681,786,7712,159,6452,684,092
DELAWAREOH656,640840,6261,016,1341,262,756
FAIRFIELDOH656,640840,6261,016,1341,262,756
FRANKLINOH656,640840,6261,016,1341,262,756
HOCKINGOH656,640840,6261,016,1341,262,756
LICKINGOH656,640840,6261,016,1341,262,756
MADISONOH656,640840,6261,016,1341,262,756
MORROWOH656,640840,6261,016,1341,262,756
PERRYOH656,640840,6261,016,1341,262,756
PICKAWAYOH656,640840,6261,016,1341,262,756
UNIONOH656,640840,6261,016,1341,262,756
BENTONOR689,804883,0761,067,4081,326,546
CLACKAMASOR802,5601,027,4381,241,9351,543,407
CLATSOPOR647,354828,7451,001,7151,244,934
COLUMBIAOR802,5601,027,4381,241,9351,543,407

Bulletin No. 2025–19 1439 May 5, 2025
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
DESCHUTESOR822,4581,052,8741,272,7341,581,646
HOOD RIVEROR879,5001,125,9491,360,9781,691,346
MULTNOMAHOR802,5601,027,4381,241,9351,543,407
WASHINGTONOR802,5601,027,4381,241,9351,543,407
YAMHILLOR802,5601,027,4381,241,9351,543,407
BUCKSPA685,824878,0001,061,2941,318,932
CHESTERPA685,824878,0001,061,2941,318,932
DELAWAREPA685,824878,0001,061,2941,318,932
MONTGOMERYPA685,824878,0001,061,2941,318,932
PHILADELPHIAPA685,824878,0001,061,2941,318,932
PIKEPA1,395,4681,786,7712,159,6452,684,092
AGUAS BUENASPR795,9271,018,9021,231,6691,530,661
AIBONITOPR795,9271,018,9021,231,6691,530,661
BARCELONETAPR795,9271,018,9021,231,6691,530,661
BARRANQUITASPR795,9271,018,9021,231,6691,530,661
BAYAMONPR795,9271,018,9021,231,6691,530,661
CAGUASPR795,9271,018,9021,231,6691,530,661
CANOVANASPR795,9271,018,9021,231,6691,530,661
CAROLINAPR795,9271,018,9021,231,6691,530,661
CATANOPR795,9271,018,9021,231,6691,530,661
CAYEYPR795,9271,018,9021,231,6691,530,661
CEIBAPR795,9271,018,9021,231,6691,530,661
CIALESPR795,9271,018,9021,231,6691,530,661
CIDRAPR795,9271,018,9021,231,6691,530,661
COMERIOPR795,9271,018,9021,231,6691,530,661
COROZALPR795,9271,018,9021,231,6691,530,661
CULEBRAPR614,191786,296950,4411,181,145
DORADOPR795,9271,018,9021,231,6691,530,661
FAJARDOPR795,9271,018,9021,231,6691,530,661
FLORIDAPR795,9271,018,9021,231,6691,530,661
GUAYNABOPR795,9271,018,9021,231,6691,530,661
GURABOPR795,9271,018,9021,231,6691,530,661
HUMACAOPR795,9271,018,9021,231,6691,530,661
JUNCOSPR795,9271,018,9021,231,6691,530,661
LAS PIEDRASPR795,9271,018,9021,231,6691,530,661
LOIZAPR795,9271,018,9021,231,6691,530,661
LUQUILLOPR795,9271,018,9021,231,6691,530,661
MANATIPR795,9271,018,9021,231,6691,530,661
MAUNABOPR795,9271,018,9021,231,6691,530,661
MOROVISPR795,9271,018,9021,231,6691,530,661
NAGUABOPR795,9271,018,9021,231,6691,530,661
NARANJITOPR795,9271,018,9021,231,6691,530,661
OROCOVISPR795,9271,018,9021,231,6691,530,661

May 5, 2025 1440 Bulletin No. 2025–19
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
RIO GRANDEPR795,9271,018,9021,231,6691,530,661
SAN JUANPR795,9271,018,9021,231,6691,530,661
SAN LORENZOPR795,9271,018,9021,231,6691,530,661
TOA ALTAPR795,9271,018,9021,231,6691,530,661
TOA BAJAPR795,9271,018,9021,231,6691,530,661
TRUJILLO ALTOPR795,9271,018,9021,231,6691,530,661
VEGA ALTAPR795,9271,018,9021,231,6691,530,661
VEGA BAJAPR795,9271,018,9021,231,6691,530,661
YABUCOAPR795,9271,018,9021,231,6691,530,661
BRISTOLRI848,9891,086,8451,313,7421,632,689
KENTRI848,9891,086,8451,313,7421,632,689
NEWPORTRI848,9891,086,8451,313,7421,632,689
PROVIDENCERI848,9891,086,8451,313,7421,632,689
WASHINGTONRI848,9891,086,8451,313,7421,632,689
BEAUFORTSC703,069900,0321,087,9411,352,096
BERKELEYSC729,600934,0041,129,0061,403,082
CHARLESTONSC729,600934,0041,129,0061,403,082
DORCHESTERSC729,600934,0041,129,0061,403,082
JASPERSC703,069900,0321,087,9411,352,096
LAWRENCESD624,803799,849966,8211,201,562
CANNONTN1,140,8291,460,4691,765,4022,193,934
CHEATHAMTN1,140,8291,460,4691,765,4022,193,934
DAVIDSONTN1,140,8291,460,4691,765,4022,193,934
DICKSONTN1,140,8291,460,4691,765,4022,193,934
MACONTN1,140,8291,460,4691,765,4022,193,934
MAURYTN1,140,8291,460,4691,765,4022,193,934
ROBERTSONTN1,140,8291,460,4691,765,4022,193,934
RUTHERFORDTN1,140,8291,460,4691,765,4022,193,934
SMITHTN1,140,8291,460,4691,765,4022,193,934
SUMNERTN1,140,8291,460,4691,765,4022,193,934
TROUSDALETN1,140,8291,460,4691,765,4022,193,934
WILLIAMSONTN1,140,8291,460,4691,765,4022,193,934
WILSONTN1,140,8291,460,4691,765,4022,193,934
ATASCOSATX643,375823,612995,6011,237,263
BANDERATX643,375823,612995,6011,237,263
BASTROPTX659,293844,0291,020,2291,267,889
BEXARTX643,375823,612995,6011,237,263
CALDWELLTX659,293844,0291,020,2291,267,889
COLLINTX650,007832,1481,005,8681,250,010
COMALTX643,375823,612995,6011,237,263
DALLASTX650,007832,1481,005,8681,250,010
DENTONTX650,007832,1481,005,8681,250,010
ELLISTX650,007832,1481,005,8681,250,010

Bulletin No. 2025–19 1441 May 5, 2025
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
GUADALUPETX643,375823,612995,6011,237,263
HAYSTX659,293844,0291,020,2291,267,889
HUNTTX650,007832,1481,005,8681,250,010
JOHNSONTX650,007832,1481,005,8681,250,010
KAUFMANTX650,007832,1481,005,8681,250,010
KENDALLTX643,375823,612995,6011,237,263
MEDINATX643,375823,612995,6011,237,263
PARKERTX650,007832,1481,005,8681,250,010
ROCKWALLTX650,007832,1481,005,8681,250,010
TARRANTTX650,007832,1481,005,8681,250,010
TRAVISTX659,293844,0291,020,2291,267,889
WILLIAMSONTX659,293844,0291,020,2291,267,889
WILSONTX643,375823,612995,6011,237,263
WISETX650,007832,1481,005,8681,250,010
BOX ELDERUT858,2751,098,7261,328,1611,650,569
DAVISUT858,2751,098,7261,328,1611,650,569
GRANDUT818,4791,047,7981,266,5631,574,033
JUABUT693,783888,1511,073,5791,334,217
MORGANUT858,2751,098,7261,328,1611,650,569
RICHUT668,579855,9101,034,5901,285,769
SALT LAKEUT725,620928,9281,122,8341,395,468
SUMMITUT1,342,4641,718,6262,077,4282,581,746
TOOELEUT725,620928,9281,122,8341,395,468
UTAHUT693,783888,1511,073,5791,334,217
WASATCHUT1,342,4641,718,6262,077,4282,581,746
WASHINGTONUT684,498876,2701,059,2181,316,337
WAYNEUT1,150,1151,472,3501,779,7632,211,813
WEBERUT858,2751,098,7261,328,1611,650,569
ALBEMARLEVA683,171874,5971,057,1421,313,799
ALEXANDRIA CITYVA1,395,4681,786,7712,159,6452,684,092
AMELIAVA777,356995,1401,202,8891,494,959
ARLINGTONVA1,395,4681,786,7712,159,6452,684,092
CHARLES CITYVA777,356995,1401,202,8891,494,959
CHARLOTTESVILLEVA683,171874,5971,057,1421,313,799
CHESAPEAKE CITYVA874,1941,119,1431,352,7881,681,195
CHESTERFIELDVA777,356995,1401,202,8891,494,959
CLARKEVA1,395,4681,786,7712,159,6452,684,092
COLONIAL HEIGHTVA777,356995,1401,202,8891,494,959
CULPEPERVA1,395,4681,786,7712,159,6452,684,092
DINWIDDIEVA777,356995,1401,202,8891,494,959
FAIRFAXVA1,395,4681,786,7712,159,6452,684,092
FAIRFAX CITYVA1,395,4681,786,7712,159,6452,684,092
FALLS CHURCH CIVA1,395,4681,786,7712,159,6452,684,092

May 5, 2025 1442 Bulletin No. 2025–19
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
FAUQUIERVA1,395,4681,786,7712,159,6452,684,092
FLUVANNAVA683,171874,5971,057,1421,313,799
FRANKLIN CITYVA874,1941,119,1431,352,7881,681,195
FREDERICKSBURGVA1,395,4681,786,7712,159,6452,684,092
GLOUCESTERVA874,1941,119,1431,352,7881,681,195
GOOCHLANDVA777,356995,1401,202,8891,494,959
GREENEVA683,171874,5971,057,1421,313,799
HAMPTON CITYVA874,1941,119,1431,352,7881,681,195
HANOVERVA777,356995,1401,202,8891,494,959
HENRICOVA777,356995,1401,202,8891,494,959
HOPEWELL CITYVA777,356995,1401,202,8891,494,959
ISLE OF WIGHTVA874,1941,119,1431,352,7881,681,195
JAMES CITYVA874,1941,119,1431,352,7881,681,195
KING AND QUEENVA777,356995,1401,202,8891,494,959
KING WILLIAMVA777,356995,1401,202,8891,494,959
LOUDOUNVA1,395,4681,786,7712,159,6452,684,092
MADISONVA1,395,4681,786,7712,159,6452,684,092
MANASSAS CITYVA1,395,4681,786,7712,159,6452,684,092
MANASSAS PARK CVA1,395,4681,786,7712,159,6452,684,092
MATHEWSVA874,1941,119,1431,352,7881,681,195
NELSONVA683,171874,5971,057,1421,313,799
NEW KENTVA777,356995,1401,202,8891,494,959
NEWPORT NEWS CIVA874,1941,119,1431,352,7881,681,195
NORFOLK CITYVA874,1941,119,1431,352,7881,681,195
PETERSBURG CITYVA777,356995,1401,202,8891,494,959
POQUOSON CITYVA874,1941,119,1431,352,7881,681,195
PORTSMOUTH CITYVA874,1941,119,1431,352,7881,681,195
POWHATANVA777,356995,1401,202,8891,494,959
PRINCE GEORGEVA777,356995,1401,202,8891,494,959
PRINCE WILLIAMVA1,395,4681,786,7712,159,6452,684,092
RAPPAHANNOCKVA1,395,4681,786,7712,159,6452,684,092
RICHMOND CITYVA777,356995,1401,202,8891,494,959
SOUTHAMPTONVA874,1941,119,1431,352,7881,681,195
SPOTSYLVANIAVA1,395,4681,786,7712,159,6452,684,092
STAFFORDVA1,395,4681,786,7712,159,6452,684,092
SUFFOLK CITYVA874,1941,119,1431,352,7881,681,195
SUSSEXVA777,356995,1401,202,8891,494,959
VIRGINIA BEACHVA874,1941,119,1431,352,7881,681,195
WARRENVA1,395,4681,786,7712,159,6452,684,092
WILLIAMSBURG CIVA874,1941,119,1431,352,7881,681,195
YORKVA874,1941,119,1431,352,7881,681,195
ST. JOHN ISLANDVI1,285,4231,645,6091,989,1262,472,047
ST. THOMAS ISLAVI776,029993,4671,200,8701,492,364

Bulletin No. 2025–19 1443 May 5, 2025
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
CHITTENDENVT663,273849,1051,026,4001,275,560
FRANKLINVT663,273849,1051,026,4001,275,560
GRAND ISLEVT663,273849,1051,026,4001,275,560
CHELANWA630,109806,655975,0691,211,771
CLARKWA802,5601,027,4381,241,9351,543,407
DOUGLASWA630,109806,655975,0691,211,771
ISLANDWA696,436891,5541,077,6741,339,292
KINGWA1,196,5441,531,8141,851,6272,301,095
KITSAPWA663,273849,1051,026,4001,275,560
PIERCEWA1,196,5441,531,8141,851,6272,301,095
SKAGITWA650,007832,1481,005,8681,250,010
SKAMANIAWA802,5601,027,4381,241,9351,543,407
SNOHOMISHWA1,196,5441,531,8141,851,6272,301,095
THURSTONWA643,375823,612995,6011,237,263
WHATCOMWA729,600934,0041,129,0061,403,082
WHITMANWA668,579855,9101,034,5901,285,769
PIERCEWI610,211781,162944,2701,173,474
ST. CROIXWI610,211781,162944,2701,173,474
JEFFERSONWV1,395,4681,786,7712,159,6452,684,092
TETONWY1,395,4681,786,7712,159,6452,684,092
All other areas – 2,794 counties (floor): $604,703$774,241$935,820
$1,163,092
.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$540,700.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2024-21 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area
purchase price safe harbors for com-
mitments to provide financing or issue
mortgage credit certificates that are
made, or (if the purchase precedes the
commitment) for residences that are
purchased, in the period that begins on
April 16, 2025, and ends on the date as
of which the safe harbors contained in
section 4.01 of this revenue procedure
are rendered obsolete by a new revenue
procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc. 2024-
21, with respect to bonds sold, or for mort-
gage credit certificates issued with respect
to bond authority exchanged, before May
16, 2025, if the commitments to provide
financing or issue mortgage credit certifi-
cates are made on or before June 15, 2025.
.03 Except as provided in section 6.04
of this revenue procedure, issuers must
use the nationwide average purchase price
limitation contained in this revenue proce-
dure for commitments to provide financ-
ing or issue mortgage credit certificates
that are made, or (if the purchase precedes
the commitment) for residences that are
purchased, in the period that begins on
April 16, 2025, and ends on the date when
the nationwide average purchase price
limitation is rendered obsolete by a new
revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2024-21 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before May 16, 2025, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
June 15, 2025.
SECTION 7. PRIOR COMMENTS
RECEIVED
In Section 7 of Rev. Proc. 2024-21,
the Treasury Department and the Internal
Revenue Service (IRS) requested com-
ments for alternate data sources to cal-
culate average area purchase prices. The
Treasury Department and the IRS have
reviewed all received comments and have
determined that no changes to the data or
the methodology for calculating average
area purchase prices will be made.

May 5, 2025 1444 Bulletin No. 2025–19
SECTION 8. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 1545-
1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
Section 3.03 of this revenue proce-
dure contains a collection of information
requirement. The purpose of the collection
of information is to verify the applicable
FHA loan limit that issuers of qualified
mortgage bonds and qualified mortgage
certificates have used to calculate the
average area purchase price for a given
MSA for purposes of §§ 143(e) and 25(c).
The collection of information is required
to obtain the benefit of using revisions to
FHA loan limits to determine average area
purchase prices. The likely respondents
are state and local governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per
respondent and/or recordkeeper: 15 min-
utes.
The estimated number of respondents
and/or recordkeepers: 60.
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 26 U.S.C. 6103.
SECTION 9. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Zoran Stojanovic and Elena
Hildebrandt of the Office of Associate
Chief Counsel (Financial Institutions &
Products). For further information regard-
ing this revenue procedure contact Ms.
Hildebrandt at (202) 317-4565 (not a toll-
free number).

Bulletin No. 2025–19 i May 5, 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.

May 5, 2025 ii Bulletin No. 2025–19
Numerical Finding List
1
Bulletin 2025–19
Announcements:
2025-2, 2025-2 I.R.B. 305
2025-3, 2025-2 I.R.B. 306
2025-4, 2025-2 I.R.B. 306
2025-1, 2025-3 I.R.B. 431
2025-5, 2025-3 I.R.B. 433
2025-6, 2025-5 I.R.B. 526
2025-8, 2025-13 I.R.B. 1384
2025-13, 2025-15 I.R.B. 1392
2025-15, 2025-18 I.R.B. 1420
Notices:
2025-1, 2025-3 I.R.B. 415
2025-2, 2025-3 I.R.B. 418
2025-4, 2025-3 I.R.B. 419
2025-5, 2025-3 I.R.B. 426
2025-3, 2025-4 I.R.B. 488
2025-7, 2025-5 I.R.B. 524
2025-9, 2025-6 I.R.B. 681
2025-10, 2025-6 I.R.B. 682
2025-11, 2025-6 I.R.B. 704
2025-13, 2025-6 I.R.B. 710
2025-6, 2025-8 I.R.B. 799
2025-8, 2025-8 I.R.B. 800
2025-12, 2025-8 I.R.B. 813
2025-14, 2025-10 I.R.B. 980
2025-15, 2025-11 I.R.B. 1089
2025-16, 2025-13 I.R.B. 1378
2025-17, 2025-14 I.R.B. 1387
2025-18, 2025-16 I.R.B. 1416
2025-19, 2025-17 I.R.B. 1418
2025-20, 2025-19 I.R.B. 1423
2025-21, 2025-19 I.R.B. 1424
2025-22, 2025-19 I.R.B. 1427
2025-23, 2025-19 I.R.B. 1428
2025-24, 2025-19 I.R.B. 1429
Proposed Regulations:
REG-117213-24, 2025-3 I.R.B. 433
REG-134420-10, 2025-4 I.R.B. 513
REG-105479-18, 2025-5 I.R.B. 527
REG-116610-20, 2025-5 I.R.B. 638
REG-115560-23, 2025-6 I.R.B. 716
REG-123525-23, 2025-6 I.R.B. 726
REG-124930-21, 2025-7 I.R.B. 772
REG-100669-24, 2025-8 I.R.B. 819
REG-101268-24, 2025-8 I.R.B. 836
REG-107420-24, 2025-8 I.R.B. 854
REG-116085-23, 2025-8 I.R.B. 865
REG-118988-22, 2025-8 I.R.B. 869
REG-107895-24, 2025-9 I.R.B. 972
REG-110878-24, 2025-9 I.R.B. 979
REG-112261-24, 2025-10 I.R.B. 983
Revenue Procedures:
2025-1, 2025-1 I.R.B. 1
2025-2, 2025-1 I.R.B. 118
2025-3, 2025-1 I.R.B. 142
2025-4, 2025-1 I.R.B. 158
2025-5, 2025-1 I.R.B. 260
2025-7, 2025-1 I.R.B. 301
2025-8, 2025-3 I.R.B. 427
2025-9, 2025-4 I.R.B. 491
2025-10, 2025-4 I.R.B. 492
2025-11, 2025-4 I.R.B. 501
2025-12, 2025-4 I.R.B. 512
2025-6, 2025-6 I.R.B. 713
2025-14, 2025-7 I.R.B. 770
2025-13, 2025-8 I.R.B. 816
2025-15, 2025-11 I.R.B. 1090
2025-16, 2025-11 I.R.B. 1100
2025-17, 2025-13 I.R.B. 1382
2025-18, 2025-19 I.R.B. 1430
Revenue Rulings:
2025-1, 2025-3 I.R.B. 307
2025-2, 2025-3 I.R.B. 309
2025-3, 2025-4 I.R.B. 443
2025-4, 2025-7 I.R.B. 758
2025-5, 2025-7 I.R.B. 767
2025-6, 2025-11 I.R.B. 1064
2025-7, 2025-13 I.R.B. 1239
2025-8, 2025-15 I.R.B. 1390
2025-9, 2025-16 I.R.B. 1415
2025-10, 2025-19 I.R.B. 1421
Treasury Decisions:
10016, 2025-3 I.R.B. 313
10020, 2025-3 I.R.B. 408
10018, 2025-4 I.R.B. 446
10019, 2025-4 I.R.B. 482
10017, 2025-5 I.R.B. 517
10028, 2025-6 I.R.B. 660
10022, 2025-8 I.R.B. 773
10026, 2025-9 I.R.B. 878
10027, 2025-9 I.R.B. 897
10029, 2025-9 I.R.B. 936
10030, 2025-11 I.R.B. 1066
10024, 2025-12 I.R.B. 1104
10023, 2025-13 I.R.B. 1259
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 23, 2024.

Bulletin No. 2025–19 iii May 5, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–19
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 23, 2024.

Internal Revenue Service
Washington, DC 20224
Official Business
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