Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 23, 2025 – November 6, 2025.
October 23, 2025: The IRS issued frequently asked questions, addressing its revisions and updates to Form 1099-K following changes resulting from the One Big Beautiful Bill Act (OBBBA). The OBBBA retroactively reinstated the reporting threshold in effect prior to the passage of the American Rescue Plan Act of 2021 (ARPA). This means that a third-party settlement organization (TPSO), which is a type of payment settlement entity, is generally not required to file a Form 1099-K. However, TPSOs will be required to file a Form 1099-K if the gross amount of reportable payment transactions to a payee exceeds $20,000 and if the number of reportable payment transactions exceeds 200. Previously, under the ARPA reporting threshold, TPSOs had to file a Form 1099-K for any payee that received more than $600 in total payments for the sales of goods or services, regardless of the number of reportable payment transactions.
October 27, 2025: The IRS reminded tax preparers that preparer tax identification numbers (PTINs) must be renewed annually and that the 2026 renewal period is now open. All 2025 PTINs will expire on December 31, 2025.
November 3, 2025: The IRS released Internal Revenue Bulletin No. 2025-45, which includes Notice 2025-61. Notice 2025-61 provides guidance on the adjusted applicable dollar amount for the Patient-Centered Outcomes Research Trust Fund (PCORTF) fee, which is imposed on issuers of specified health plans and plan sponsors of applicable self-insured health plans to fund PCORTF. Notice 2025-61 specifically provides the increased adjusted applicable dollar amount for determining the PCORTF fee as $3.84 (from the previous set amount of $3.47) for all policies and plans ending on or after October 1, 2025, and before October 1, 2026. The IRS explained that the amount was calculated by US Department of the Treasury economists based on the percentage increase in the projected per capita amount of National Health Expenditures, which was published by the US Department of Health and Human Services in June 2025.
November 5, 2025: The IRS issued Notice 2025-62, providing guidance on penalty relief for taxable year 2025 in connection with the implementation of new information reporting requirements related to the deductions for qualified tips and qualified overtime compensation to reflect amendments resulting from the OBBBA. Notice 2025-62 specifically provides relief for taxable year 2025 from the penalty under Section 6721 for failure to file correct information returns and the penalty under Section 6722 for failure to furnish correct payee statements. The IRS also announced that guidance on how taxpayers can claim these deductions on their tax return for the 2025 tax year is forthcoming.
The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).
Suzanne Golshanara, a law clerk in the Washington, DC, office, also contributed to this post.
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