Internal Revenue Bulletin 2025-26 (PDF rendition): IRS Notices

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Bulletin No. 2025–26
June 23, 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.
EXEMPT ORGANIZATIONS
Announcement 2025-17, page 1620.
The Internal Revenue Service has revoked its determination
that Little Kings and Queens Inc. qualifies as an organization
described in sections 501(c)(3) and 170(c)(2) of the Internal
Revenue Code of 1986. The revocation is effective January
1, 2020
Announcement 2025-18, page 1621.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
TAX CONVENTIONS
Notice 2025-27, page 1611.
This notice provides interim guidance regarding the applica-
tion of the corporate alternative minimum tax, as added to
title 26 of the United States Code (Internal Revenue Code) by
the Inflation Reduction Act of 2022. Specifically, this notice
provides an optional simplified method for determining appli-
cable corporation status under § 59(k) of the Internal Reve-
nue Code. This notice also waives certain additions to tax
under § 6655 with respect to a corporation’s CAMT liability
under § 55.
Notice 2025-30, page 1615.
This notice publishes the inflation adjustment factor and
reference price for calendar year 2025 for the renewable
electricity production credit under section 45 of the Internal
Revenue Code. The 2025 inflation adjustment factor and
reference price are used in determining the availability of
the credit and apply to calendar year 2025 sales of kilo-
watt hours of electricity produced in the United States or a
possession thereof from qualified energy resources. This
notice also provides the credit amounts for calendar year
2025 under section 45.
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.
June 23, 2025 Bulletin No. 2025–26

Part III
Interim Simplified Method
for Determining Applicable
Corporation Status; Waiver
of Certain Additions to Tax
under Section 6655
Notice 2025-27
SECTION 1. OVERVIEW
This notice provides interim guidance
regarding the application of the corporate
alternative minimum tax (CAMT) and
relief from certain additions to tax for an
applicable corporation’s underpayment of
estimated tax under § 6655 of the Inter-
nal Revenue Code (Code).
1
Section 3 of
this notice provides an optional simplified
method for determining applicable corpo-
ration status (interim simplified method).
Section 4 of this notice waives certain
additions to tax under § 6655 with respect
to a corporation’s CAMT liability under
§ 55.
Prior to the publication of any final
regulations relating to the CAMT, the
Department of the Treasury (Treasury
Department) and the Internal Revenue
Service (IRS) intend to issue a notice
of proposed rulemaking that revises the
CAMT proposed regulations described
in section 2.02(2) of this notice to
include a method for determining appli-
cable corporation status similar to the
interim simplified method as well as
other revisions.
SECTION 2. BACKGROUND
.01 Overview of the CAMT. Section
10101 of Public Law 117-169, 136 Stat.
1818, 1818-1828 (August 16, 2022),
commonly referred to as the Inflation
Reduction Act of 2022, amended § 55 to
impose the CAMT based on the “adjusted
financial statement income” (AFSI) of an
“applicable corporation” for taxable years
beginning after December 31, 2022. The
definition of “applicable corporation” is
provided in § 59(k)(1) and described in
section 2.03 of this notice. Section 55(a)
provides that, for the taxable year of an
applicable corporation, the amount of
CAMT imposed by § 55 equals the excess
(if any) of (i) the tentative minimum tax
for the taxable year, over (ii) the sum of the
regular tax, as defined in § 55(c), for the
taxable year plus the tax imposed under
§ 59A. Section 55(b)(2)(A) provides that,
in the case of an applicable corporation,
the tentative minimum tax for the taxable
year is the excess of (i) 15 percent of AFSI
for the taxable year (as determined under
§ 56A), over (ii) the CAMT foreign tax
credit for the taxable year (as determined
under § 59(l)). In the case of any corpora-
tion that is not an applicable corporation,
§ 55(b)(2)(B) provides that the tentative
minimum tax for the taxable year is zero.
.02 Prior guidance relating to the
CAMT.
(1) Prior notices. Notice 2023-7,
2023-3 I.R.B. 390 (January 17, 2023),
announced that the Treasury Department
and the IRS intended to issue proposed
regulations addressing the application
of the CAMT. Notice 2023-7 provided
interim guidance on certain issues relat-
ing to the CAMT, including the treat-
ment of certain Federal income tax cred-
its under the CAMT and a safe harbor
method for determining whether a corpo-
ration is an applicable corporation sub-
ject to the CAMT. Notice 2023-20, 2023-
10 I.R.B. 523 (March 6, 2023), Notice
2023-64, 2023-40 I.R.B. 974 (October
2, 2023), and Notice 2024-10, 2024-3
I.R.B. 406 (January 16, 2024), provided
additional interim guidance to further
clarify the application of the CAMT. Tax-
payers may generally rely on the interim
guidance provided in Notice 2023-7,
Notice 2023-20, and Notice 2023-64 for
taxable years ending on or before Sep-
tember 13, 2024. Taxpayers may rely on
Notice 2024-10 for “Covered CFC Dis-
tributions” (as defined therein) received
on or before September 13, 2024, and
the rules for determining the applicable
financial statement (AFS) of a tax con-
solidated group for taxable years ending
before September 13, 2024.
(2) CAMT Proposed Regulations. On
September 13, 2024, the Treasury Depart-
ment and the IRS published a notice of
proposed rulemaking (REG-112129-23)
in the Federal Register (89 F.R. 75062)
containing proposed regulations address-
ing the application of the CAMT (CAMT
Proposed Regulations). Proposed § 1.59-
2(g) of the CAMT Proposed Regulations
would provide a simplified method for
determining applicable corporation sta-
tus. The CAMT Proposed Regulations
also provide reliance rules, which are
described in section 2.06 of this notice.
On December 26, 2024, the Treasury
Department and the IRS published in the
Federal Register (89 F.R. 104909) tech-
nical corrections to the CAMT Proposed
Regulations. Numerous comments were
submitted in response to the CAMT Pro-
posed Regulations, which the Treasury
Department and the IRS continue to con-
sider and study.
.03 Definition of applicable corpora-
tion.
(1) Applicable corporation. Section
59(k)(1)(A) provides that, for purposes
of §§ 55 through 59, the term “applica-
ble corporation” means, with respect to
any taxable year, any corporation (other
than an S corporation, a regulated invest-
ment company, or a real estate investment
trust) that meets either of the two average
annual AFSI tests provided in § 59(k)(1)
(B), for one or more taxable years that
(1) are prior to that taxable year and (2)
end after December 31, 2021.
(2) Average annual AFSI tests. The
“general AFSI test” of § 59(k)(1)(B)(i)
(described in section 2.03(2)(a) of this
notice) and the “FPMG AFSI test” of
§ 59(k)(1)(B)(ii) (described in section
2.03(2)(b) of this notice) are collectively
referred to as “the average annual AFSI
tests” in this notice.
(a) General AFSI test. Under the gen-
eral AFSI test of § 59(k)(1)(B)(i), if a cor-
poration is not a member of a foreign-par-
ented multinational group (FPMG) (as
1
Unless otherwise specified, all "section" or "§" references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).
Bulletin No. 2025–26 1611 June 23, 2025

defined in § 59(k)(2)(B)) for any taxable
year, the corporation meets the average
annual AFSI test for a taxable year if its
average annual AFSI (determined without
regard to the adjustment under § 56A(d)
for financial statement net operating losses
(FSNOLs)) for the 3-taxable-year period
ending with such taxable year exceeds
$1 billion.
(b) FPMG AFSI test. Under the FPMG
AFSI test of § 59(k)(1)(B)(ii), if a corpo-
ration is a member of an FPMG for any
taxable year, the corporation meets the
average annual AFSI test if—
(i) the corporation meets the general
AFSI test for the taxable year (determined
after applying the FPMG rule in § 59(k)
(2)), and
(ii) the average annual AFSI of the cor-
poration (determined without regard to
the FPMG rule in § 59(k)(2) and without
regard to the adjustment under § 56(d) for
FSNOLs) for the 3-taxable-year period
ending with such taxable year is $100 mil-
lion or more.
(3) Proposed § 1.59-2. Proposed
§ 1.59-2 would provide rules under
§ 59(k) for determining whether a cor-
poration is an applicable corporation for
purposes of §§ 55 through 59. Proposed
§ 1.59-2(c) would provide general rules
regarding the average annual AFSI tests
under § 59(k)(1)(B) and for determining
AFSI for purposes of these tests.
.04 Definition of AFSI and adjustments
relevant to interim simplified method.
(1) Definition of AFSI. For purposes
of §§ 55 through 59, the term “AFSI”
means, with respect to any corporation
for any taxable year, the net income
or loss of the taxpayer set forth on the
taxpayer’s AFS for that taxable year,
adjusted as provided in § 56A. Section
56A(c) provides general adjustments to
be made to AFSI. Section 56A(c)(15)
authorizes the Secretary of the Treasury
or the Secretary’s delegate (Secretary)
to issue regulations or other guidance
to provide for such adjustments to AFSI
as the Secretary determines necessary to
carry out the purposes of § 56A.
(2) AFSI adjustments for certain Fed-
eral and foreign income taxes. Section
56A(c)(5) provides the general rule that
AFSI is appropriately adjusted to disre-
gard any Federal income taxes, or income,
war profits, or excess profits taxes (within
the meaning of § 901) with respect to a for-
eign country or possession of the United
States, which are taken into account on the
taxpayer’s AFS. Proposed § 1.56A-8(b)
would provide general rules for adjust-
ing AFSI for certain income taxes under
§ 56A(c)(5).
(3) AFSI adjustments with respect
to certain tax credits. Section 56A(c)
(9) requires AFSI to be appropriately
adjusted to disregard any amount treated
as a payment against the Federal income
tax pursuant to an election under § 48D(d)
or § 6417 and included in the net income
or loss set forth on the taxpayer’s AFS.
However, if such amount is otherwise
disregarded under the adjustment rule in
§ 56A(c)(5), the adjustment in § 56A(c)
(9) does not apply. Consistent with
§ 56A(c)(9), and pursuant to the authority
granted by § 56A(c)(15) and (e), proposed
§ 1.56A-12 would provide that AFSI is
adjusted to disregard any amount treated
as a payment against the tax imposed by
subtitle A of the Code pursuant to an elec-
tion under § 48D(d) or § 6417 and any
amount received from the transfer of an
eligible credit that is not included in the
gross income of the CAMT entity under
§ 6418(b) or that is treated as tax-exempt
income under § 6418(c)(1)(A), to the
extent the amount is not otherwise disre-
garded under proposed § 1.56A-8, among
other AFSI adjustments.
(4) AFSI adjustments for tax-exempt
entities. Section 56A(c)(12) requires AFSI
to be appropriately adjusted, in the case of
an organization subject to tax under § 511,
to take into account only AFSI (i) of an
unrelated trade or business of such organi-
zation, as defined in § 513, or (ii) derived
from debt-financed property, as defined
in § 514, to the extent that income from
such property is treated as unrelated busi-
ness taxable income. Proposed § 1.56A-
14 would provide rules implementing
§ 56A(c)(12).
.05 Simplified method for determining
applicable corporation status.
(1) Section 59(k)(3)(A) authorizes the
Secretary to issue regulations or other
guidance providing a simplified method
for determining whether a corporation is
an applicable corporation subject to the
CAMT.
(2) Under that authority, proposed
§ 1.59-2(g) would provide a simplified
method for determining applicable cor-
poration status, which is generally consis-
tent with section 5 of Notice 2023-7. Pro-
posed § 1.59-2(g)(2) would provide that,
under the simplified method, the average
annual AFSI tests are applied with spec-
ified modifications. First, the simplified
method thresholds used for the average
annual AFSI tests in § 59(k)(1)(B) would
be reduced from $1 billion to $500 mil-
lion and from $100 million to $50 million,
respectively. In addition, proposed § 1.59-
2(g)(2)(iii)(B), as corrected, would pro-
vide that, in determining AFSI under the
simplified method, the only adjustments
made are those in proposed § 1.56A-8(b)
(concerning taxes) and proposed § 1.56A-
14 (concerning tax-exempt entities) and,
solely for purposes of the $100 million
second prong of the FPMG AFSI test,
proposed § 1.56A-7 (regarding adjust-
ment for income effectively connected to
a United States trade or business). Fur-
ther, in determining the AFSI of a person
whose financial results are reflected on a
consolidated AFS, those members of a test
group whose financial results are reflected
on the consolidated AFS would be treated
as a single CAMT entity for purposes of
proposed § 1.56A-1(c)(3) and (4) so that
consolidation entries would be taken into
account, except for those consolidation
entries that eliminate transactions between
persons that are treated as neither a single
employer under § 52(a) or (b) nor mem-
bers of an FPMG. See proposed § 1.59-
2(g)(2)(iii)(A). Finally, the simplified
method would permit a corporation that
has an AFS year that differs from its tax-
able year to determine its AFSI by using
its AFS year. See proposed § 1.59-2(g)(2)
(iv).
(3) Comments submitted in response
to the simplified method provided under
proposed § 1.59-2(g) have generally rec-
ommended raising the thresholds for the
simplified method under proposed § 1.59-
2(g) in order to reduce potential compli-
ance burdens for corporations that exceed
the thresholds but are not expected to be
applicable corporations. The comments
indicated that such corporations are cur-
rently required to determine applicable
corporation status by applying the average
June 23, 2025 1612 Bulletin No. 2025–26

Bulletin No. 2025–26 1613 June 23, 2025
annual AFSI tests under § 59(k)(1)(B) or
proposed § 1.59-2(c), and to comply with
applicable reporting requirements, as they
do not satisfy the simplified method in
proposed § 1.59-2(g).
(4) In addition, comments submitted in
response to the simplified method provided
under proposed § 1.59-2(g) requested that
the adjustments to AFSI for certain tax
credits under proposed § 1.56A-12, which
apply for purposes of calculating AFSI for
determining applicable corporation status
under proposed § 1.59-2(c), should also
apply when calculating AFSI under the
simplified method in proposed § 1.59-2(g)
(2). The comments noted that the exclusion
of the AFSI adjustments under proposed
§ 1.56A-12 from the calculation of AFSI
under the simplified method in proposed
§ 1.59-2(g)(2) could cause certain corpo-
rations that are not expected to be applica-
ble corporations to exceed the thresholds
in the proposed simplified method and,
accordingly, to bear increased compliance
burdens and higher compliance costs to
calculate AFSI under the average annual
AFSI tests in § 59(k)(1)(B) or proposed
§ 1.59-2(c) and to comply with applicable
reporting requirements.
.06 Proposed applicability dates and
reliance on the CAMT Proposed Reg-
ulations. Proposed § 1.59-2 and other
“specified regulations” (as defined in
the Proposed Applicability Dates and
Reliance on the Proposed Regulations
section of the preamble to the CAMT
Proposed Regulations) are proposed to
apply to taxable years ending after Sep-
tember 13, 2024. In addition, the CAMT
Proposed Regulations provide that a tax-
payer may rely on proposed § 1.59-2 and
other specified regulations for any tax-
able year ending on or before September
13, 2024, provided that the taxpayer, and
each member of its test group determined
under proposed § 1.59-2 for that taxable
year, consistently follow all of the spec-
ified regulations (and other enumerated
proposed rules) in their entirety for that
taxable year and each subsequent taxable
year until the first taxable year to which
the final regulations are applicable. In
addition, taxpayers may rely on one or
more other sections of the CAMT Pro-
posed Regulations for any taxable years
ending on or before the date the CAMT
Proposed Regulations are published as
final in the Federal Register, provided
that the taxpayer and each member of
its test group for the taxable year consis-
tently follow that section in its entirety
and also follow all of the specified regu-
lations (and other enumerated proposed
rules) in their entirety in that taxable year
and each subsequent taxable year until
the first taxable year that final regulations
are applicable.
.07 Estimated taxes.
(1) Section 6655(a) imposes an addi-
tion to tax for failure by a corporation
to make a sufficient and timely pay-
ment of estimated income tax. Section
6655(c) and (d)(1)(A) generally pro-
vide that, in the case of a corporation,
estimated income tax is required to be
paid in four installments and the amount
of any required installment is 25 per-
cent of the required annual payment.
Generally, under § 6655(d)(1)(B), the
required annual payment is the lesser of
two amounts described in § 6655(d)(1)
(B)(i) and (ii). The amount described in
§ 6655(d)(1)(B)(i) is 100 percent of the
tax shown on the return for the taxable
year. The amount described in § 6655(d)
(1)(B)(ii) is 100 percent of the tax shown
on the taxpayer’s return for the preced-
ing taxable year, so long as the preceding
taxable year was a full twelve months
long and the return for such year showed
a liability for tax. However, pursuant to
§ 6655(d)(2), in the case of a large cor-
poration (as defined under § 6655(g)(2)),
the amount described in § 6655(d)(1)(B)
(ii) may not be used to reduce the amount
of an installment payment other than the
first installment payment for the taxable
year. In special circumstances, other
rules specified in § 6655 or elsewhere
may also apply.
(2) On June 7, 2023, the Treasury
Department and the IRS issued Notice
2023-42, 2023-26 I.R.B. 1085, which pro-
vided a waiver of the addition to tax under
§ 6655 with respect to a corporation’s
CAMT liability under § 55 for any taxable
year that begins after December 31, 2022,
and before January 1, 2024.
(3) On April 15, 2024, the Treasury
Department and the IRS issued Notice
2024-33, 2024-18 I.R.B. 959, which pro-
vided a limited waiver of the addition to
tax under § 6655 to the extent the amount
of any underpayment is attributable to a
portion of a corporation’s CAMT liabil-
ity. The relief provided in Notice 2024-33
applied only for the purpose of calculating
the installment of estimated tax by a cor-
porate taxpayer that was due on or before
April 15, 2024, or May 15, 2024 (in the
case of a fiscal year taxpayer with a tax-
able year beginning in February 2024),
with respect to a taxable year that began
in 2024.
(4) On June 13, 2024, the Treasury
Department and the IRS issued Notice
2024-47, 2024-27 I.R.B. 1, which
extended the relief provided in Notice
2024-33. Under Notice 2024-47, the lim-
ited waiver of the addition to tax under
§ 6655 provided by Notice 2024-33 was
extended to apply for the purpose of cal-
culating any installment of estimated tax
by a corporate taxpayer that was due on or
before August 15, 2024, with respect to a
taxable year that began in 2024.
(5) Finally, on September 12, 2024,
the Treasury Department and the IRS
issued Notice 2024-66, 2024-40 I.R.B.
682, which provided a waiver of the addi-
tion to tax under § 6655 with respect to
a corporation’s CAMT liability under
§ 55 for any taxable year that begins after
December 31, 2023, and before January 1,
2025. Notice 2024-66 also incorporated
the relief provided in Notice 2024-33
and Notice 2024-47 and obsoleted those
notices.
SECTION 3. INTERIM SIMPLIFIED
METHOD
.01 Purpose of the interim guidance.
To reduce compliance burdens and costs
for certain corporations, this section 3
provides an interim simplified method to
determine applicable corporation status
using thresholds of $800 million and $80
million and calculating AFSI by using the
AFSI adjustments described in proposed
§ 1.56A-12 as well as other AFSI adjust-
ments.
.02 Definition of AFS Consolidation
Entries. For purposes of this section 3, the
term “AFS Consolidation Entries” means
the financial accounting journal entries
that are made in preparing a consolidated
financial statement for a financial state-

June 23, 2025 1614 Bulletin No. 2025–26
ment group in order to present the finan-
cial results of that group as if all mem-
bers of the group were a single economic
entity, including journal entries:
(1) To eliminate the effect of transac-
tions between members of the financial
statement group;
(2) To report amounts that are not
recorded in the separate books and records
of one or more members of the financial
statement group; and
(3) To correct or otherwise adjust
amounts that are reported in the separate
books and records of one or more mem-
bers of the financial statement group.
.03 Interim simplified method for deter-
mining applicable corporation status.
(1) Interim simplified method. A cor-
poration may apply the interim simplified
method described in this section 3.03 for
purposes of determining whether it is an
applicable corporation under § 59(k)(1).
Under the interim simplified method, a
corporation determines whether it is an
applicable corporation by applying the
rules in § 59(k)(1) and (2) with the fol-
lowing modifications:
(a) The general AFSI test in § 59(k)(1)
(B)(i) (including for purposes of § 59(k)
(1)(B)(ii)(I)) is applied by substituting
“$800,000,000” for “$1,000,000,000.”
(b) The second prong of the FPMG
AFSI test in § 59(k)(1)(B)(ii)(II) is
applied by substituting “$80,000,000” for
“$100,000,000.”
(2) Rules for determining AFSI. For
purposes of this section 3.03, AFSI is
determined—
(a) Except as provided in section
3.03(2)(c) of this notice,
(i) with regard to the adjustments set
forth in § 56A(c)(2)(A), (c)(2)(B), (c)
(5), (c)(9), and (c)(12) and, solely for pur-
poses of applying § 59(k)(1)(B)(ii)(II), the
adjustment set forth in § 56A(c)(4), and
(ii) without regard to any other adjust-
ments set forth in § 56A(c) and (d),
(b) By adjusting AFSI to disregard (to
the extent not already disregarded under
§ 56A(c)(9)):
(i) Any amount received from the
transfer of an eligible credit, as defined in
§ 6418(f)(1)(A), that is not includible in the
gross income of the taxpayer by applica-
tion of § 6418(b) or is treated as tax exempt
under § 6418(c)(1)(A), provided that such
amount (or portion thereof) is not other-
wise disregarded under § 56A(c)(5),
(ii) Any amount received pursuant to
an election under §§ 48D(d)(2) or 6417(c)
that is treated as tax exempt income under
§ 48D(d)(2)(A)(i)(III) or 6417(c)(1)(C),
provided that such amount is not other-
wise disregarded under § 56A(c)(5),
(iii) Any amount paid by the transferee
taxpayer, as defined in § 6418(a), to the
eligible taxpayer, as defined in § 6418(f)
(2), as consideration for the transfer of the
eligible tax credit, as defined in § 6418(f)
(1)(A), provided that the amount is not
otherwise disregarded under § 56A(c)(5),
and
(iv) Any increase in the transferee tax-
payer’s net income or loss set forth on the
taxpayer’s AFS resulting from the utili-
zation of the eligible tax credit, provided
that the increase is not otherwise disre-
garded under § 56A(c)(5), and
(c) After taking into account AFS Con-
solidation Entries, except those that elim-
inate transactions between persons not
treated as a single employer under § 52(a)
or between entities not included in an
FPMG, as applicable.
(3) AFS year different than taxable year.
For purposes of this section 3.03, if a corpo-
ration has an AFS that covers a period (AFS
year) that differs from its taxable year—
(a) Section 59(k)(1)(B)(i) and (ii)(II)
are applied by substituting “3-AFS-year
period ending during such taxable year”
for “3-taxable-year-period ending with
such taxable year” in each place those
phrases appear, and
(b) Section 59(k)(1)(E) is applied by
substituting “AFS year” for “taxable year”
and “3-AFS years” for “3-taxable years”
in each place those phrases appear.
.04 Effect of exceeding the thresholds
under the interim simplified method. If a
corporation applies the interim simplified
method described in section 3.03 of this
notice for a taxable year and determines
that its AFSI (as determined under section
3.03 of this notice) exceeds the relevant
interim simplified method thresholds, then
the corporation will be an applicable cor-
poration for such taxable year only if it is
determined to be an applicable corpora-
tion under § 59(k)(1) or, if the corporation
follows the CAMT Proposed Regulations,
proposed § 1.59-2(c).
.05 Applicability dates and reliance.
A corporation may use the interim sim-
plified method provided in section 3.03
of this notice for determining applica-
ble corporation status for any taxable
year ending on or before the date that a
Treasury Decision adopting a simplified
method pursuant to § 59(k)(3)(A) is pub-
lished in the Federal Register and for
which the original Federal income tax
return has not been filed as of June 23,
2025. A corporation’s use of the interim
simplified method to determine that it is
not an applicable corporation for a tax-
able year will not cause the corporation
to become subject to, or to violate, the
reliance rules, including the consistency
requirements, provided in the preamble
of the CAMT Proposed Regulations for
such taxable year.
.06 Instructions to be modified. The
instructions to Form 4626, Alternative
Minimum Tax – Corporations and Sched-
ule K of Form 1120, U.S. Corporation
Income Tax Return (or other appropriate
instructions in the Form 1120 series),
will be modified, as necessary, to reflect
the availability of the interim simplified
method provided in section 3.03 of this
notice. The modified instructions will be
posted on https://www.irs.gov.
SECTION 4. LIMITED WAIVER OF
ADDITION TO TAX
.01 Waiver. In light of the continued
uncertainty with respect to tax positions
determined by applicable corporations
following the publication of the CAMT
Proposed Regulations, and in the interest
of sound tax administration, the IRS will
waive the addition to tax under § 6655
with respect to a corporation’s CAMT
liability under § 55 for any taxable year
that begins after December 31, 2024, and
before January 1, 2026 (Covered CAMT
Year). Accordingly, for a Covered CAMT
Year, a corporation’s required install-
ments of estimated tax need not include
amounts attributable to its CAMT liabil-
ity under § 55 to prevent the imposition
of an addition to tax under § 6655. If a
corporation fails to timely pay its CAMT
liability under § 55 when due, other sec-
tions of the Code may apply; for exam-
ple, additions to tax could be imposed

Bulletin No. 2025–26 1615 June 23, 2025
under § 6651 if payment of the CAMT
liability is not made by the due date
(without regard to any extension) of the
corporation’s return.
.02 Instructions to be modified. The
instructions to Form 2220, Underpay-
ment of Estimated Tax by Corporations,
will be modified, as necessary, to clarify
that no addition to tax will be imposed
under § 6655 based on a corporation’s
failure to make an estimated tax payment
of its CAMT liability under § 55 for any
Covered CAMT Year, and that a taxpayer
may exclude such amounts when calcu-
lating the amount of its required annual
payment on Form 2220. The modified
instructions will be posted on https://
www.irs.gov.
.03 Instructions to avoid penalty
notice. Taxpayers seeking the relief pro-
vided in this notice (affected taxpayers)
must file Form 2220 with their Federal
income tax return, even if they owe no
estimated tax penalty. The Form 2220
must be completed without including
the CAMT liability from Schedule J of
Form 1120, U.S. Corporation Income
Tax Return (or other appropriate line of
the corporation’s income tax return in the
Form 1120 series). Affected taxpayers
must also include an amount of estimated
tax penalty on Line 34 of their Form 1120
(or other appropriate line of the corpo-
ration’s income tax return in the Form
1120 series), even if that amount is zero.
Failure to follow these instructions could
result in affected taxpayers receiving a
penalty notice that will require an abate-
ment request to apply the relief provided
by this notice.
.04 Applicability. The waiver of
the addition to tax imposed by § 6655
described in section 4.01 of this notice
applies for any Covered CAMT Year.
SECTION 5. ADDITIONAL
INTERIM GUIDANCE AND
REGULATIONS
.01 The Treasury Department and the
IRS intend to issue additional interim
guidance regarding application of the
CAMT to respond to other comments sub-
mitted in response to the CAMT Proposed
Regulations. The Treasury Department
and the IRS anticipate that the additional
interim guidance will address several
issues, including among others:
(1) the interaction of the CAMT and
the tonnage tax regime enacted by the
American Jobs Creation Act of 2004, Pub-
lic Law 108-357, 118 Stat. 1418 (October
22, 2004),
(2) how unrealized gains and losses
on certain investment assets reported for
financial statement purposes are taken
into account for purposes of determining
AFSI,
(3) alternative rules for determining a
partner’s distributive share of partnership
AFSI,
(4) AFSI adjustments resulting from
certain transactions between a partner and
partnership,
(5) AFSI adjustments resulting from
certain corporate transactions, and
(6) alternative rules for early reliance
on the CAMT Proposed Regulations.
.02 The Treasury Department and the
IRS anticipate that new proposed regula-
tions issued to revise the CAMT Proposed
Regulations will incorporate rules similar
to the interim simplified method described
in section 3 of this notice, the additional
interim guidance addressing the issues
described in section 5.01(1) through (6) of
this notice, and other issues described in
interim guidance.
SECTION 6. DRAFTING AND
CONTACT INFORMATION
The principal authors of this notice
are Madeline Padner of the Office of the
Associate Chief Counsel (Income Tax
and Accounting) and Alexander Wu of
the Office of the Associate Chief Counsel
(Procedure and Administration). Other
personnel from the Treasury Department
and the IRS participated in its develop-
ment. For further information regarding
section 3 of this notice, please contact
Madeline Padner at (202) 317-7006 (not a
toll-free number). For further information
regarding section 4 of this notice, please
contact Alexander Wu at (202) 317-6845
(not a toll-free number).
Credit for Renewable
Electricity Production and
Publication of Inflation
Adjustment Factor and
Reference Price for
Calendar Year 2025
Notice 2025-30
This notice publishes the inflation
adjustment factor and reference price for
calendar year 2025 for the renewable elec-
tricity production credit under section 45
of the Internal Revenue Code (section 45
credit). The 2025 inflation adjustment fac-
tor and reference price are used in deter-
mining the availability of the credit and
apply to calendar year 2025 sales of kilo-
watt hours of electricity produced in the
United States or a possession thereof from
qualified energy resources.
BACKGROUND
Section 45 was amended by section
13101 of Public Law 117-169, 136 Stat.
1818 (August 16, 2022), commonly
known as the Inflation Reduction Act of
2022 (IRA). The IRA changed the manner
in which the section 45 credit amounts are
calculated for any qualified facility placed
in service after December 31, 2021.
As amended by the IRA, section 45(b)
(6)(A) provides that, in the case of any
qualified facility that satisfies the require-
ments of section 45(b)(6)(B), the credit
amount determined under section 45(a)
(determined after the application of sec-
tion 45(b)(1) through (5) and without
regard to section 45(b)(6)) is equal to
such amount multiplied by 5. A qualified
facility satisfies the requirements of sec-
tion 45(b)(6)(B) if it is placed in service
after December 31, 2021, and it is one of
the following: (i) a facility with a maxi-
mum net output of less than 1 megawatt
(as measured in alternating current); (ii)
a facility the construction of which began
prior to January 29, 2023, which is the
date that is 60 days after the publication of
the guidance with respect to the require-

June 23, 2025 1616 Bulletin No. 2025–26
ments of section 45(b)(7)(A) (prevailing
wage requirements) and section 45(b)(8)
(apprenticeship requirements);
1
or (iii) a
facility that satisfies the requirements of
section 45(b)(7)(A) and (8). The IRA also
added bonus credit amounts with respect
to qualified facilities placed in service after
December 31, 2022, that meet domestic
content requirements under section 45(b)
(9)
2
or energy community requirements
under section 45(b)(11).
3

The IRA amended the phaseout of the
section 45 credit for wind facilities under
section 45(b)(5) such that it does not apply
to facilities placed in service after Decem-
ber 31, 2021. The IRA also added a new
phaseout of the section 45 credit under
section 45(b)(10) in the case of qualified
facilities placed in service after December
31, 2022, for taxpayers making an elec-
tive payment election under section 6417.
The IRA also amended the credit amount
reduction under section 45(b)(3) in the
case of qualified facilities the construction
of which began after August 16, 2022.
The IRA amended section 45(d)(4) to
restore the section 45 credit for electric-
ity produced in solar energy facilities in
the case of qualified facilities placed in
service after December 31, 2021, and the
construction of which began before Janu-
ary 1, 2025. Effective for facilities placed
in service after December 31, 2022, the
IRA (1) removed the one-half reduction
of the credit amount under section 45(b)
(4)(A) for qualified hydropower facilities
and marine and hydrokinetic renewable
energy facilities and (2) amended the defi-
nition of marine and hydrokinetic renew-
able energy under section 45(c)(10) and
the definition of a marine and hydrokinetic
renewable energy facility under section
45(d)(11). The IRA also extended certain
deadlines in the definitions under section
45(d) for wind facilities, closed-loop bio-
mass facilities, open-loop biomass facil-
ities, geothermal facilities, landfill gas
facilities, trash facilities, qualified hydro-
power facilities, and marine and hydroki-
netic renewable energy facilities.
Section 45(a) provides that the renew-
able electricity production credit for any
tax year is an amount equal to the product
of the kilowatt hours of specified electric-
ity produced by the taxpayer and sold to
an unrelated person during the tax year
multiplied by 1.5 cents (in the case of a
qualified facility placed in service before
January 1, 2022) or 0.3 cents (in the case
of a qualified facility placed in service
after December 31, 2021). This electricity
must be produced from qualified energy
resources and at a qualified facility during
the 10-year period beginning on the date
the facility was originally placed in ser-
vice.
Section 45(b)(1) provides that the
amount of the credit determined under
section 45(a) is reduced by an amount
which bears the same ratio to the amount
of the credit as the amount by which the
reference price for the calendar year in
which the sale occurs exceeds 8 cents,
bears to 3 cents. Under section 45(b)(2),
the 1.5 cent (or 0.3 cent) amount in sec-
tion 45(a) and the 8 cent amount in section
45(b)(1) are each adjusted by multiplying
such amount by the inflation adjustment
factor for the calendar year in which the
sale occurs. In the case of any qualified
facility placed in service before January
1, 2022, if any amount as increased under
section 45(b)(2) is not a multiple of 0.1
cent, such amount is rounded to the near-
est multiple of 0.1 cent. In the case of any
qualified facility placed in service after
December 31, 2021, if the 0.3 cent amount
as increased under section 45(b)(2) is not
a multiple of 0.05 cent, such amount is
rounded to the nearest multiple of 0.05
cent.
In the case of electricity produced in
open-loop biomass facilities, landfill gas
facilities, trash facilities, qualified hydro-
power facilities, and, if placed in ser-
vice before January 1, 2023, marine and
hydrokinetic renewable energy facilities,
section 45(b)(4)(A) requires the amount in
effect under section 45(a)(1) for such cal-
endar year (determined before rounding as
required by section 45(b)(2)) to be reduced
by one-half. As amended by the IRA, the
one-half reduction under section 45(b)(4)
(A) no longer applies to qualified hydro-
power facilities and marine and hydroki-
netic renewable energy facilities placed in
service after December 31, 2022.
Section 45(b)(5) provides that in the
case of any qualified wind facility placed
in service before January 1, 2022, the
amount of the credit determined under
section 45(a) (determined after the appli-
cation of section 45(b)(1), (2), and (3) and
without regard to section 45(b)(5)) shall
be reduced by (A) in the case of any facil-
ity the construction of which began after
December 31, 2016, and before January 1,
2018, 20 percent, (B) in the case of any
facility the construction of which began
after December 31, 2017, and before Jan-
uary 1, 2019, 40 percent, (C) in the case
of any facility the construction of which
began after December 31, 2018, and
before January 1, 2020, 60 percent, and
(D) in the case of any facility the con-
struction of which began after December
31, 2019, and before January 1, 2022, 40
percent.
Section 45(c)(1) defines qualified
energy resources as wind, closed-loop
biomass, open-loop biomass, geother-
mal energy, solar energy, municipal solid
waste, qualified hydropower production,
and marine and hydrokinetic renewable
energy.
Section 45(d)(1) defines a qualified
facility using wind to produce electric-
ity as any facility owned by the taxpayer
that was originally placed in service after
December 31, 1993, and the construction
of which began before January 1, 2025.
See section 45(e)(7) for rules relating to
the inapplicability of the credit to electric-
ity sold to utilities under certain contracts.
Section 45(d)(2)(A) defines a qualified
facility using closed-loop biomass to pro-
duce electricity as any facility owned by
the taxpayer that was originally placed in
service after December 31, 1992, and the
construction of which began before Jan-
uary 1, 2025, or owned by the taxpayer
which before January 1, 2025, was origi-
nally placed in service and modified to use
closed-loop biomass to co-fire with coal,
with other biomass, or with both, but only
if the modification is approved under the
1
See §§ 1.45-6, 1.45-7, 1.45-8, and 1.45-12 of the Income Tax Regulations for additional information regarding the requirements of section 45(b)(6)(B).
2
See Notice 2023-38, 2023-22 I.R.B. 872 (May 12, 2023), Notice 2024-41, 2024-24 I.R.B. 1615 (May 16, 2024), corrected at IR 2024-147 (May 24, 2024), and Notice 2025-08, 2025-8 I.R.B.
800 (February 18, 2025), for additional information regarding the domestic content bonus credit.
3
See Notice 2024-30, 2024-16 I.R.B. 878 (April 15, 2024), for additional information regarding the energy community bonus credit.

Bulletin No. 2025–26 1617 June 23, 2025
Biomass Power for Rural Development
Programs or is part of a pilot project of
the Commodity Credit Corporation as
described in 65 FR 63052. For purposes
of section 45(d)(2)(A)(ii), a facility shall
be treated as modified before January 1,
2025, if the construction of such modifica-
tion began before such date. Section 45(d)
(2)(C) provides that in the case of a qual-
ified facility described in section 45(d)(2)
(A)(ii), the 10-year period referred to in
section 45(a) is treated as beginning no
earlier than the date of the enactment of
section 45(d)(2)(C)(i) (October 22, 2004),
and if the owner of such facility is not the
producer of the electricity, the person eli-
gible for the credit allowable under section
45(a) is the lessee or the operator of such
facility. A qualified facility using closed-
loop biomass includes a new unit placed
in service after the date of the enactment
of section 45(d)(2)(B) (October 3, 2008)
in connection with a qualified facility
using closed-loop biomass, but only to the
extent of the increased amount of electric-
ity produced at the facility by reason of
such new unit.
Section 45(d)(3)(A) defines a quali-
fied facility using open-loop biomass to
produce electricity as any facility owned
by the taxpayer which in the case of a
facility using agricultural livestock waste
nutrients, was originally placed in service
after the date of the enactment of section
45(d)(3)(A)(i)(I) (October 22, 2004) and
the construction of which began before
January 1, 2025, and the nameplate capac-
ity rating of which is not less than 150
kilowatts, and in the case of any other
facility, the construction of which began
before January 1, 2025. In the case of any
facility described in section 45(d)(3)(A),
if the owner of such facility is not the pro-
ducer of the electricity, section 45(d)(3)
(C) provides that the person eligible for
the credit allowable under section 45(a) is
the lessee or the operator of such facility.
A qualified facility using open-loop bio-
mass includes a new unit placed in service
after the date of the enactment of section
45(d)(3)(B) (October 3, 2008) in connec-
tion with a qualified facility using open-
loop biomass, but only to the extent of the
increased amount of electricity produced
at the facility by reason of such new unit.
Section 45(d)(4) defines a qualified
facility using geothermal energy to pro-
duce electricity as any facility owned by
the taxpayer that was originally placed in
service after the date of the enactment of
section 45(d)(4) (October 22, 2004) and
the construction of which began before
January 1, 2025. A qualified facility using
geothermal energy does not include any
property described in section 48(a)(3) the
basis of which is taken into account by the
taxpayer for purposes of determining the
energy credit under section 48.
As amended by the IRA and effective
for solar energy facilities placed in service
after December 31, 2021, section 45(d)(4)
also defines a qualified facility using solar
energy to produce electricity as any facil-
ity owned by the taxpayer that was origi-
nally placed in service after the date of the
enactment of section 45(d)(4) (October
22, 2004) and the construction of which
began before January 1, 2025. A qualified
facility using solar energy does not include
any property described in section 48(a)(3)
the basis of which is taken into account by
the taxpayer for purposes of determining
the energy credit under section 48.
Section 45(d)(6) defines a qualified
facility using gas derived from the bio-
degradation of municipal solid waste to
produce electricity as any facility owned
by the taxpayer that was originally placed
in service after the date of the enactment
of section 45(d)(6) (October 22, 2004) and
the construction of which began before
January 1, 2025.
Section 45(d)(7) defines a qualified
facility (other than a facility described in
section 45(d)(6)) that uses municipal solid
waste to produce electricity as any facil-
ity owned by the taxpayer that was origi-
nally placed in service after the date of the
enactment of section 45(d)(7) (October
22, 2004) and the construction of which
began before January 1, 2025. A quali-
fied facility using municipal solid waste
includes a new unit placed in service in
connection with a facility placed in ser-
vice on or before the date of the enactment
of section 45(d)(7), but only to the extent
of the increased amount of electricity pro-
duced at the facility by reason of such new
unit.
Section 45(d)(9) defines a qualified
facility producing qualified hydroelectric
production (as described in section 45(c)
(8)) as (i) any facility producing incremen-
tal hydropower production, but only to the
extent of its incremental hydropower pro-
duction attributable to efficiency improve-
ments or additions to capacity described in
section 45(c)(8)(B) placed in service after
the date of the enactment of section 45(d)
(9) (August 8, 2005) and before January
1, 2025, and (ii) any other facility placed
in service after the date of the enactment
of section 45(d)(9) (August 8, 2005) and
the construction of which began before
January 1, 2025. Section 45(d)(9)(B) pro-
vides that, in the case of a qualified facil-
ity described in section 45(d)(9)(A), the
10-year period referred to in section 45(a)
shall be treated as beginning on the date
the efficiency improvements or additions
to capacity are placed in service. Section
45(d)(9)(C) provides that for purposes
of section 45(d)(9)(A)(i), an efficiency
improvement or addition to capacity shall
be treated as placed in service before Jan-
uary 1, 2025, if the construction of such
improvement or addition began before
such date.
As amended by the IRA, section 45(d)
(11) provides that, in the case of a facil-
ity producing electricity from marine
and hydrokinetic renewable energy, the
term “qualified facility” means any facil-
ity owned by the taxpayer which has a
nameplate capacity rating of at least 150
kilowatts (or at least 25 kilowatts in the
case of a facility placed in service after
December 31, 2022), and was originally
placed in service on or after the date of
the enactment of section 45(d)(11) (Octo-
ber 3, 2008) and the construction of which
began before January 1, 2025.
Section 45(e)(2)(A) requires the Secre-
tary to determine and publish in the Fed-
eral Register each calendar year the infla-
tion adjustment factor and the reference
price for such calendar year. The inflation
adjustment factor and the reference price
for the 2025 calendar year were published
in the Federal Register at 90 FR 22438 on
May 27, 2025.
Section 45(e)(2)(B) defines the infla-
tion adjustment factor for a calendar year
as a fraction the numerator of which is the
GDP implicit price deflator for the pre-
ceding calendar year and the denominator
of which is the GDP implicit price defla-
tor for the calendar year 1992. The term
“GDP implicit price deflator” means the
most recent revision of the implicit price
deflator for the gross domestic product as

June 23, 2025 1618 Bulletin No. 2025–26
computed and published by the Depart-
ment of Commerce before March 15 of
the calendar year.
Section 45(e)(2)(C) provides that the
reference price with respect to a calen-
dar year is the Secretary’s determination
of the annual average contract price per
kilowatt hour of electricity generated
from the same qualified energy resource
and sold in the previous year in the
United States. Only contracts entered
into after December 31, 1989, are taken
into account.
INFLATION ADJUSTMENT
FACTOR AND REFERENCE PRICE
The inflation adjustment factor for
calendar year 2025 for qualified energy
resources is 1.9971.
The reference price for calendar year
2025 for facilities producing electric-
ity from wind (based upon information
provided by the Department of Energy)
is 3.1 cents per kilowatt hour. The ref-
erence prices for facilities producing
electricity from closed-loop biomass,
open-loop biomass, geothermal energy,
solar energy, municipal solid waste,
qualified hydropower production, and
marine and hydrokinetic renewable
energy have not been determined for
calendar year 2025.
PHASEOUT CALCULATION
Because the 2025 reference price for
electricity produced from wind (3.1 cents
per kilowatt hour) does not exceed 8
cents multiplied by the inflation adjust-
ment factor (1.9971), the phaseout of the
credit provided in section 45(b)(1) does
not apply to such electricity sold during
calendar year 2025. However, section
45(b)(5) provides an additional phaseout
of the credit for wind facilities placed
in service before January 1, 2022, and
the construction of which began after
December 31, 2016. For electricity pro-
duced from closed-loop biomass, open-
loop biomass, geothermal energy, solar
energy, municipal solid waste, qualified
hydropower production, and marine
and hydrokinetic renewable energy, the
phaseout of the credit provided in section
45(b)(1) does not apply to such electric-
ity sold during calendar year 2025.
CREDIT AMOUNT FOR A
QUALIFIED FACILITY PLACED
IN SERVICE BEFORE JANUARY 1,
2022
As required by section 45(b)(2), the 1.5
cent amount provided in section 45(a)(1)
is adjusted by multiplying such amount
by the inflation adjustment factor for the
calendar year in which the sale occurs.
If any amount as increased under section
45(b)(2) is not a multiple of 0.1 cent, such
amount is rounded to the nearest multi-
ple of 0.1 cent. In the case of electricity
produced in open-loop biomass facilities,
landfill gas facilities, trash facilities, quali-
fied hydropower facilities, and marine and
hydrokinetic renewable energy facilities,
section 45(b)(4)(A) requires the amount in
effect under section 45(a)(1) for such cal-
endar year (before rounding to the nearest
0.1 cent as required by section 45(b)(2)) to
be reduced by one-half.
4

Under the calculation required by sec-
tion 45(b)(2), the credit for renewable
electricity production for calendar year
2025 determined under section 45(a) is 3
cents per kilowatt hour on the sale of elec-
tricity produced in any qualified facility
placed in service before January 1, 2022,
from the qualified energy resources of
wind, closed-loop biomass, and geother-
mal energy, and 1.5 cents per kilowatt
hour on the sale of electricity produced
in any qualified facility placed in service
before January 1, 2022, from the qualified
energy resources of open-loop biomass,
landfill gas, trash, qualified hydropower,
and marine and hydrokinetic renewable
energy.
CREDIT AMOUNT FOR A
QUALIFIED FACILITY PLACED IN
SERVICE AFTER DECEMBER 31,
2021
As required by section 45(b)(2), the 0.3
cent amount provided in section 45(a)(1)
is adjusted by multiplying such amount by
the inflation adjustment factor for the cal-
endar year in which the sale occurs. If the
0.3 cent amount as adjusted for inflation
is not a multiple of 0.05 cent, the amount
is rounded to the nearest multiple of 0.05
cent. In the case of electricity produced
in open-loop biomass facilities, landfill
gas facilities, trash facilities, qualified
hydropower facilities, and marine and
hydrokinetic renewable energy facilities,
section 45(b)(4)(A) requires the amount
in effect under section 45(a)(1) for such
calendar year (determined before round-
ing as required by section 45(b)(2)) to be
reduced by one-half.
Under the calculation required by
section 45(b)(2), the credit for renew-
able electricity production for calendar
year 2025 determined under section
45(a) is 0.6 cents per kilowatt hour on
the sale of electricity produced in any
qualified facility placed in service after
December 31, 2021, from the qualified
energy resources of wind, closed-loop
biomass, geothermal energy, and solar
energy, and 0.3 cents per kilowatt hour
on the sale of electricity produced in
any qualified facility placed in service
after December 31, 2021, from the qual-
ified energy resources of open-loop bio-
mass, landfill gas and trash. The credit
for renewable electricity production for
calendar year 2025 determined under
section 45(a) is also 0.3 cents per kilo-
watt hour on the sale of electricity pro-
duced in any qualified facility placed in
service after December 31, 2021, and
before January 1, 2023, from the quali-
fied energy resources of qualified hydro-
power and marine and hydrokinetic
renewable energy.
CREDIT AMOUNT FOR
QUALIFIED HYDROPOWER
FACILITIES AND MARINE AND
HYDROKINETIC RENEWABLE
ENERGY FACILITIES PLACED IN
SERVICE AFTER DECEMBER 31,
2022
The one-half reduction under section
45(b)(4)(A) no longer applies to quali-
4
As amended by the IRA and discussed later in this notice, the one-half reduction under section 45(b)(4)(A) no longer applies to qualified hydropower facilities and marine and hydrokinetic
renewable energy facilities placed in service after December 31, 2022.

Bulletin No. 2025–26 1619 June 23, 2025
fied hydropower facilities and marine
and hydrokinetic renewable energy
facilities placed in service after Decem-
ber 31, 2022. Accordingly, under the
calculation required by section 45(b)
(2), the credit for renewable electric-
ity production for calendar year 2025
determined under section 45(a) is 0.6
cents per kilowatt hour on the sale of
electricity produced in any qualified
facility placed in service after Decem-
ber 31, 2022, from the qualified energy
resources of qualified hydropower and
marine and hydrokinetic renewable
energy.
DRAFTING AND CONTACT
INFORMATION
The principal author of this notice
is Charles Hyde of the Office of Asso-
ciate Chief Counsel (Energy, Credits,
and Excise Tax). For further information
regarding this notice contact Mr. Hyde at
(202) 317-6853 (not a toll-free number).

June 23, 2025 1620 Bulletin No. 2025–26
Part IV
Deletions From Cumulative List of Organizations, Contributions to Which are
Deductible Under Section 170 of the Code
Announcement 2025-17
The Internal Revenue Service has revoked its determination that the organization listed below qualifies as an organization described
in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.
Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announce-
ment in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a
deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or
determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities
or omissions of the organization that brought about this revocation.
If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described
in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on
January 1, 2018 and would end on the date the court first determines the organization is not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband
and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the
organization that were the basis for revocation.
The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the
“Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code:
NAME OF ORGANIZATIONEFFECTIVE DATE OF REVOCATIONLOCATION
LITTLE KINGS AND QUEENS INC.1/1/2020BUFORD GA

Bulletin No. 2025–26 1621 June 23, 2025
Deletions From Cumulative List of Organizations, Contributions to Which are
Deductible Under Section 170 of the Code
Announcement 2025-18
The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in
sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.
Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announce-
ment in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a
deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or
determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities
or omissions of the organization that brought about this revocation.
If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described
in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on
June 6, 2025, and would end on the date the court first determines the organization is not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband
and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the
organization that were the basis for revocation.
Name Of OrganizationEffective Date of RevocationLocation
Global Rescue Welfare League, Inc.07/01/2021Columbia, SC
Global Rescue Welfare League, Inc.07/01/2021Williston, SC
Providing Hope VA01/01/2020Loris, SC
Houston Serenity Place Inc.01/01/2020Spring, TX
Preserve Reasonable Shoreline 07/01/2021Bainbridge Island, WA

Bulletin No. 2025–26 i June 23, 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.

June 23, 2025 ii Bulletin No. 2025–26
Numerical Finding List
1
Bulletin 2025–26
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
2025-7, 2025-25 I.R.B. 1600
2025-9, 2025-25 I.R.B. 1601
2025-10, 2025-25 I.R.B. 1602
2025-11, 2025-25 I.R.B. 1603
2025-12, 2025-25 I.R.B. 1604
2025-14, 2025-25 I.R.B. 1605
2025-16, 2025-25 I.R.B. 1609
2025-17, 2025-26 I.R.B. 1620
2025-18, 2025-26 I.R.B. 1621
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
2025-25, 2025-20 I.R.B. 1445
2025-26, 2025-20 I.R.B. 1445
2025-29, 2025-20 I.R.B. 1445
2025-27, 2025-26 I.R.B. 1611
2025-30, 2025-26 I.R.B. 1615
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
2025-19, 2025-21 I.R.B. 1447
2025-20, 2025-22 I.R.B. 1448
2025-21, 2025-22 I.R.B. 1448
2025-23, 2025-24 I.R.B. 1476
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
2025-11, 2025-23 I.R.B. 1451
2025-12, 2025-23 I.R.B. 1471
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. 2025–26 iii June 23, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–26
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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INTERNAL REVENUE BULLETIN
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