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IRS Roundup February 17 – March 14, 2025

by , , and | Mar 14, 2025 |

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025.

Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition in recent weeks and issued significantly less guidance than normal. We did not publish the IRS Roundup regularly during these weeks as we awaited new guidance from the agency.

February 19, 2025: The IRS issued Revenue Ruling 2025-6, providing the March 2025 short-, mid-, and long-term applicable federal rates for purposes of Section 1274(d) of the Internal Revenue Code (Code), as well as other provisions.

February 21, 2025: The IRS issued Notice 2025-15, providing guidance on the alternative method for furnishing health insurance coverage statements to individuals, as required by Code Sections 6055 and 6056. This alternative method allows entities to post a clear and conspicuous notice on their websites, informing individuals that they can request a copy of their health coverage statement. This notice must be posted by the due date for furnishing the statements and retained through October 15, 2026. The guidance applies to statements for calendar years after 2023.

March 5, 2025: The IRS issued Revenue Procedure 2025-17, providing guidance for individuals who failed to meet the eligibility requirements of Code Section 911(d)(1) (foreign earned income exclusion) for 2024 because of adverse conditions in certain foreign countries. The revenue procedure lists specific countries, including Ukraine, Iraq, Haiti, and Bangladesh, where war, civil unrest, or similar conditions precluded normal business conduct. Individuals who left these countries on or after specified dates in 2024 may still qualify for the foreign earned income exclusion if they can demonstrate that they would have met the eligibility requirements but for these adverse conditions.

March 5, 2025: The IRS issued Notice 2025-16, providing adjustments to the limitation on housing expenses for 2025 under Code Section 911. These adjustments account for geographic differences in housing costs relative to those in the United States. The notice includes a detailed table listing the adjusted housing expense limitations for locations worldwide. It also allows taxpayers to apply the 2025 adjusted limitations to their 2024 taxable year if the new limits are higher.

March 6, 2025: The IRS issued Revenue Ruling 2025-7, providing interest rates for tax overpayments and underpayments for the second quarter of 2025 in accordance with Code Section 6621.

March 11, 2025: The IRS issued Notice 2025-17, providing updates on the corporate bond monthly yield curve, spot segment rates, and 24-month average segment rates used under Code Sections 417(e)(3) and 430(h)(2). The notice includes the interest rate on 30-year Treasury securities and the 30-year Treasury weighted average rate for plan years beginning before 2008. It also specifies the minimum funding requirements for single-employer plans, the methodology for determining monthly corporate bond yield curves, and the adjusted 24-month average segment rates for March 2025. Additionally, the notice outlines the permissible range of rates for calculating current liability for multiemployer plans.



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Weekly IRS Roundup March 13 – March 17, 2023

by | Mar 20, 2023 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023.

March 13, 2023: The IRS released Internal Revenue Bulletin 2023-11, which highlights the following:

  • Notice 2023-21: This notice postpones the beginning of the lookback periods under Section 6511 for certain taxpayers to file a claim for refund. Affected taxpayers include those who had tax returns due from April 15, 2020 to July 15, 2020, or from April 15, 2021 to May 17, 2021, and due to the COVID-19 pandemic, those due dates were postponed by Notice 2020-23 or Notice 2021-21 to July 15, 2020 or May 17, 2021, respectively.
  • Treasury Decision 9972: These final regulations amend the rules for filing certain returns and statements electronically to reflect changes made by the Taxpayer First Act of 2019 and to promote electronic filing.
  • Notice 2023-19: This notice provides guidance on the corporate bond monthly yield curve, corresponding spot segment rates and the 24-month average segment rates for February 2023. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.
  • REG 122286-18: These proposed regulations provide rules relating to the use of forfeitures in qualified retirement plans, including a deadline for the use of forfeitures in defined contribution plans, and clarify that forfeitures arising in any defined contribution plan may be used for one or more of the following purposes, as specified in the plan, to (1) pay plan administrative expenses, (2) reduce employer contributions under the plan or (3) increase benefits in other participants’ accounts in accordance with plan terms.
  • Action on Decision 2023-2: The IRS announced nonacquiescence to the US Tax Court’s decision in Complex Media, Inc. v. Commissioner, T.C. Memo. 2021-14, that the parties’ failure to report transactions fully or consistently should not be a major factor in a decision of whether to allow a taxpayer to disavow the form of its transactions and to the standard the Court applied to allow a petitioner to disavow its form. The IRS also announced nonacquiescence to the court’s determination that the fair market value of a “Deferred Payment Right” for purposes of Section 351(b)(1) is not equal to its issue price.
  • Treasury Decision 9973: This document contains final regulations that treat members of a consolidated group as a single US shareholder in certain cases for purposes of Section 951(a)(2)(B). The final regulations affect consolidated groups that own stock of foreign corporations.

March 13, 2023: The IRS announced that Danny Werfel began work as the 50th Commissioner of the IRS. Werfel was confirmed by the US Senate on March 9, 2023, and his term will run through November 12, 2027. You can read more about his confirmation
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Weekly IRS Roundup April 3 – April 9, 2022

by | Apr 11, 2022 | ,

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 3, 2022 – April 9, 2022. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

April 4, 2022: The IRS issued a news release, announcing that the application period for 2023 grants under the Low Income Taxpayer Clinic (LITC) program, an IRS program created to assist organizations in providing pro bono representation to low-income and English as a second language (ESL) taxpayers in federal tax disputes, will begin on or around May 2, 2022.

April 4, 2022: The IRS issued a news release, announcing that, in advance of the federal tax filing deadline, free face-to-face tax preparation assistance will be provided at Taxpayer Assistance Centers around the country on April 9, 2022.

April 5, 2022: The IRS issued proposed regulations amending the eligibility requirements for the premium tax credit under Section 36B of the Code. The proposed regulations generally provide that, for purposes of determining eligibility for the premium tax credit, the affordability of an employer-sponsored health plan with respect to an employee’s family members is determined based on the cost of covering the employee and their family members, rather than on the cost of covering the employee individually.

April 6, 2022: The IRS issued a news release, reminding taxpayers who make estimated tax payments that the due date for the first estimated tax installment is April 18, 2022.

April 8, 2022: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Le Chen in our Washington, DC, office for this week’s roundup.



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Tax Reform Insight: Eligibility Requirements for Reduced Tax Rate on FDII for Royalties

by , and | Jul 18, 2018 | ,

A domestic corporation’s royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income (FDII). To qualify, the licensee must be a foreign person, and the intangible property must be used outside the US for the ultimate benefit of an unrelated foreign person.

For example, the lower rate generally should be available for royalties from licensing intangible property to an unrelated foreign person for use: (1) in the production and sale of products to foreign customers; (2) to provide services to foreign customers; or (3) to sublicense the intangible property to foreign persons.

Royalties from licensing intangible property to an unrelated US corporation that is for use outside the US may not qualify for FDII benefits. Such royalties should qualify, however, if instead the license is with a foreign subsidiary of the US corporation, or if a foreign subsidiary otherwise economically is considered the licensee.

The 13.125 percent tax rate is also available for certain royalties derived from licensing intangible property to related foreign persons. For example, royalties generally should qualify if the related foreign person uses the intangibles outside the United States to (1) produce and sell products to unrelated foreign customers; (2) provide services to unrelated foreign customers, or (3) sublicense the intangibles to unrelated foreign persons. (more…)



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