This notice provides transitional relief from backup withholding tax liability and associated penalties for any DeFi broker that fails to withhold and pay the backup withholding tax: (1) for any sale of a digital asset effected by a DeFi broker during calendar year 2027; and (2) for any sale of a digital asset effected by a DeFi broker during calendar year 2028 for a customer (payee), if the DeFi broker submits that payee’s name and tax identification number (TIN) combination to the IRS’s TIN Matching Program and receives a response that the name and TIN combination matches IRS records. For sales effected before January 1, 2029, this notice also provides that (1) a DeFi broker may treat a customer as an exempt foreign person if the customer has not previously been classified as a U.S. person by the DeFi broker, and the information that the DeFi broker has for the customer includes a residence address that is not a U.S. address and (2) the IRS will not impose penalties with respect to any decrease in the value of received digital assets between the time of the transaction and the time the broker liquidates 24 percent of the received digital assets, provided the broker immediately liquidates the digital assets.

On December 30, 2024, Revenue Procedure 2025-1 was published with an incorrect user fee for requests for tax treaty limitation of benefits determinations. I.R.B. 2025-1. This revenue procedure contains the correct user fee for requests for tax treaty limitation of benefits determinations. Rev. Proc. 2025-1 is modified.

26 CFR § 601.201: Rulings and determination letters.

This document contains final regulations that amend the definition of “coverage month” and amend certain other rules in existing income tax regulations regarding the computation of an individual taxpayer’s premium tax credit. The coverage month amendment generally provides that, in computing a premium tax credit, a month may be a coverage month for an individual if the amount of the premium paid, including by advance payments of the premium tax credit, for the month for the individual’s coverage is sufficient to avoid termination of the individual’s coverage for that month. The final regulations also amend the existing regulations relating to the amount of enrollment premiums used in computing the taxpayer’s monthly premium tax credit if a portion of the monthly enrollment premium for a coverage month is unpaid. Finally, the final regulations clarify when an individual is considered to be not eligible for coverage under a State’s Basic Health Program. The final regulations affect taxpayers who enroll themselves, or enroll a family member, in individual health insurance coverage through a Health Insurance Exchange and may be allowed a premium tax credit for the coverage.

26 CFR 1.36B-1-6

The Revenue Procedure provides updated guidance, modifying and superseding Rev. Proc. 85-18, to be consistent with amendments made to section 530, as well as to clarify the definition of “employee”, the timeliness requirement for filing required returns, and the application of the reasonable basis safe haven.

[26 CFR 601.401] Employment Taxes (Also: Sections 3102, 3111, 3301, 3403, 31.3102-1, 31.3111-4, 31.3301-1, 31.3403-1)

This Revenue Ruling addresses the application of Section 530 of the Revenue Act of 1978 (section 530), section 3509 rates, and the requirements to issue a Notice of Employment Tax Determination Under IRC § 7436 (§ 7436 Notice) in several distinct factual situations.

I.R.C. Section 3509—Determination of Employer’s Liability for Certain Employment Taxes (Also: I.R.C. Section 7436 and Section 530 of the Revenue Act of 1978)

Section 5000D of the Internal Revenue Code imposes an excise tax on applicable sales of designated drugs by manufacturers, producers, and importers during statutorily defined periods. This revenue procedure provides a safe harbor and safe harbor percentage that manufacturers, producers, and importers may use to identify applicable sales of designated drugs made during such periods.

26 CFR 601.601: Rules and Regulations. (Also Part I, Section 5000D; § 47.5000D-3.)

These proposed regulations would amend 26 CFR 1.1502-80(d) to clarify the non-applicability of section 357(c) to consolidated groups.

This revenue procedure provides procedural and clarifying guidance applicable to section 48E(h). This guidance is being issued simultaneously with final regulations concerning the technology neutral low-income communities bonus credit program (Program) established pursuant to the Inflation Reduction Act of 2022 as section 48E(h) of the Internal Revenue Code. Applicants investing in certain clean electricity generation facilities may apply for an allocation of environmental justice capacity limitation (Capacity Limitation) to increase the amount of the clean electricity investment credit for the taxable year in which the facility is placed in service. The final regulations describe definitions and requirements that are applicable for the Program. The final regulations affect applicants seeking allocations of Capacity Limitation to claim the increased clean electricity investment credit under section 48E for the taxable year in which the facility is placed in service.

26 CFR 601.201: Rulings and determination letters.

These final regulations amend consolidated return regulations and controlled group of corporations regulations to reflect statutory changes, modernize language, and enhance clarity.