/>iCheck out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2025 – April 17, 2025.
April 4, 2025: The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax issues that should be addressed via regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. A list of factors the IRS considers when selecting projects for inclusion is outlined in the notice.
April 9, 2025: The US Department of the Treasury (Treasury), along with the IRS and the Financial Crimes Enforcement Network, eliminated 15 rules and guidance materials, in addition to two rules already rescinded by the Office of the Comptroller of the Currency. The stated purpose of these actions was to remove rules that the government says are now obsolete and hamper the growth of US small businesses. These actions were some of the many that the Treasury says it will take over the next several months to eliminate unnecessary IRS rules and to “unleash the regulated banking sector.”
April 10, 2025: US President Donald Trump signed legislation blocking an IRS reporting rule that would have required decentralized digital asset platforms to report statistics showing customers’ gross sales on their platforms.
April 11, 2025: The IRS issued Notice 2025-24, providing penalty relief under Section 6707A(a) of the Internal Revenue Code to participants in micro-captive reportable transactions that fail to timely file (i.e., by April 14, 2025) certain disclosure statements as required under Section 6011; Treas. Reg. §§ 1.6011-10(h)(2) or 1.6011-11(h)(2); Section 6111; and Treas. Reg. §§ 1.6011-10(h)(3) or 1.6011-11(h)(3)). Participants will only qualify for relief if they file the required disclosure statement with the Office of Tax Shelter Analysis by July 31, 2025.
April 14, 2025: The IRS issued Notice 2025-22, providing for the elimination of extraneous and unnecessary Internal Revenue Bulletin guidance. This notice was prompted by the issuance of Executive Order 14219 on February 19, 2025. The purpose of Executive Order 14219 is to focus the IRS’s limited enforcement resources on regulations “squarely authorized by constitutional Federal statutes” while eliminating “overbearing and burdensome” regulations and “ending Federal overreach.” In Notice 2025-22, the IRS eliminated several current sources of guidance and stated that it anticipates revoking or obsoleting hundreds of similar guidance documents in the near future.
April 15, 2025: The IRS issued Notice 2025-21, providing updates on the corporate bond monthly yield curve, spot segment rates used under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the Code. This notice also provides guidance on the interest rates for 30-year Treasury securities and the 30-year Treasury weighted average for plan years beginning before 2008.
April 17, 2025: The IRS issued Notice 2025-23, announcing its intent to publish a notice of proposed rulemaking, proposing the removal of Treas. Reg. § 1.6011-18 (Basis Shifting TOI Regulations) from the Income Tax Regulations. As of January 14, 2025, the Basis Shifting TOI Regulations identified certain partnership-related-party basis adjustment transactions as transactions of interest. Since becoming effective in January, taxpayers have criticized the Basis Shifting TOI Regulations as imposing complex, burdensome, and retroactive disclosure obligations on ordinary activities, rendering compliance costly and creating uncertainty for business activities. Thus, pursuant to Executive Order 14219, directing agencies to remove certain regulations through the Department of Government Efficiency initiative, the Treasury identified this as a burdensome regulation that should be removed. Moreover, given the Treasury’s intent to remove the Basis Shifting TOI Regulations, Notice 2025-23 states that the IRS will waive penalties under § 6707A(a) for any failure to file a Form 8886, § 6707(a) for any failure to file a Form 8918, and § 6708 for any failure to maintain a list under § 6112.
The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).
