In this release, we cover key highlights from Internal Revenue Bulletin 2025-9, including estate and gift tax guidance, corporate tax regulations, and new rules on micro-captive transactions.
Access to Full IRS Bulletins in PDF format
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.
EMPLOYEE PLANS, EXCISE TAX
REG-110878-24, page 979.
This document withdraws a notice of proposed rulemaking that appeared in the Federal Register on October 28, 2024, regarding coverage of certain preventive services under the Affordable Care Act.
ESTATE TAX, GIFT TAX
T.D. 10027, page 897.
The final Treasury Decision provides guidance for section 2801, which was added to the Internal Revenue Code by section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008, Public Law 110–245 (122 Stat. 1624), effective June 17, 2008. Section 2801, which is the sole section of new Chapter 15 of subtitle B (relating to taxes on transfers of property), imposes a transfer tax on U.S. citizens and residents, including trusts, who receive, directly or indirectly, covered gifts and covered bequests from covered expatriates.
INCOME TAX
REG-107895-24, page 972.
These proposed regulations provide guidance regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.
T.D. 10026, page 878.
This document contains final regulations regarding certain disregarded payments that give rise to deductions for foreign tax purposes and potential double non-taxation of income. The final regulations affect domestic corporate owners that make or receive such payments. This document also announces additional transition relief for the application of the dual consolidated loss (“DCL”) rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax.
T.D. 10029, page 936.
This document contains final regulations that identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions, a type of reportable transaction, and certain other micro-captive transactions as transactions of interest, another type of reportable transaction.