Learn more about key tax updates from IRB 2025-13, including interest rates, foreign income exclusions, clean hydrogen credits, and U.S.-Swiss tax treaty changes.
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The Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.
ADMINISTRATIVE
Rev. Rul. 2025-7, page 1239.
Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the calendar quarter beginning April 1, 2025, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.
INCOME TAX
Notice 2025-16, page 1378.
Notice 2025-16 provides for adjustments to the limitation on housing expenses for purposes of section 911 of the Internal Revenue Code for the 2025 tax year. These adjustments are made on the basis of geographic differences in housing costs relative to housing costs in the United States. If the limitation on housing expenses is higher for the 2025 tax year than the adjusted limitations on housing expenses provided in Notice 2024-31, qualified taxpayers may apply the adjusted limitations in this notice for the 2025 tax year to their 2024 tax year.
Rev. Proc. 2025-17, page 1382.
Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. However, if their tax home is in a foreign country and they meet either the bona fide residence test or the physical presence test, they can choose to exclude from their income a limited amount of their foreign earned income (up to $126,500 for 2024). Both the bona fide residence test and the physical presence test contain minimum time requirements. Revenue Procedure 2025-17 provides a waiver under section 911(d)(4) for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2025-17 adds Ukraine, Iraq, Haiti, and Bangladesh to the list of waiver countries for tax year 2024 for which the minimum time requirements are waived.
T.D. 10023, page 1259.
These final regulations provide rules for the new section 45V tax credit for the production of qualified clean hydrogen that was added by the Inflation Reduction Act of 2022. The final regulations provide guidance on how to claim the section 45V credit, a production tax credit, the amount of which is dependent on the quantity and emissions intensity of the hydrogen produced. The final regulations also provide guidance on the election to treat qualified property that is part of a specified clean hydrogen production facility as energy property under section 48, which is part of the investment tax credit under section 46.
TAX CONVENTIONS
Announcement 2025-8, page 1384.
The competent authorities of the United States and the Swiss Confederation have entered a Competent Authority Arrangement under paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income signed at Washington on October 2, 1996, as amended by the Protocol, signed on September 23, 2009, regarding certain U.S. and Swiss pension or other retirement arrangements, including individual retirement savings plans, that may be eligible for benefits under paragraph 3 of Article 10 (Dividends).