Bulletin No. 2026–23

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Bulletin No. 2026–23

June 1, 2026

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE, INCOME TAX

T.D. 10048, page 1558.

The final regulations modify information reporting obligations

with respect to sales or exchanges of certain interests in

partnerships owning inventory or unrealized receivables.

Specifically, the final regulations eliminate a regulatory

requirement that partnerships furnish partners that bought

or sold interests in the partnership certain computational

information by January 31 of the year following the calendar

year in which the sale or exchange occurred. As a result, the

final regulations result in partnerships having additional time

(generally, until the due date of the partnership’s return) to

compute and furnish such information.

begins on August 1, 2026, and ends on July 31, 2027.

The 2026 Cumulative List identifies recent changes in the

qualification requirements of the Internal Revenue Code

that were not taken into account during the first three

remedial amendment cycles for defined benefit qualified

pre-approved plans and that will be taken into account by

the IRS with respect to the form of a plan submitted to

the IRS for Cycle 4.

EXEMPT ORGANIZATIONS

Announcement 2026-10, page 1569.

EMPLOYEE PLANS

Revocation of IRC 501(c)(3) Organizations for failure to meet

the code section requirements. Contributions made to the

organizations by individual donors are no longer deductible

under IRC 170(b)(1)(A).

Notice 2026-31, page 1562.

SPECIAL ANNOUNCEMENT

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment

rates for April 2026 used under § 417(e)(3)(D), the

24-month average segment rates applicable for May

2026, and the 30-year Treasury rates, as reflected by

the application of § 430(h)(2)(C)(iv).

Notice 2026-34, page 1565.

This notice sets forth the 2026 Cumulative List of

Changes in Plan Qualification Requirements for Defined

Benefit Qualified Pre-approved Plans (2026 Cumulative

List). The 2026 Cumulative List will assist providers

applying to the Internal Revenue Service (IRS) for opinion letters for the fourth remedial amendment cycle

for defined benefit qualified pre-approved plans (Cycle

4) under the IRS’s pre-approved plan program. Cycle 4

began on April 1, 2025. The Cycle 4 submission period

Finding Lists begin on page ii.

AOD 2026-1, page 1556.

This Action on Decision announces the IRS’s acquiescence

in result only to the April 2, 2024 Tax Court decision

Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner,

162 T.C. 148. In that case, the Tax Court held that the

then-applicable version of IRC 7508A(d) provided for an

automatic and mandatory 60-day postponement of certain

tax-related deadlines for all taxpayers in Ohio affected by

the federally declared disaster for the COVID-19 pandemic,

beginning January 20, 2020, and ending on March 20,

2020. In so holding, the Tax Court invalidated Treas. Reg.

301.7508A(g)(1) and (2), which limit the non-pension-related time-sensitive acts that are postponed for the mandatory 60-day postponement period to acts determined to be

postponed by the Secretary’s exercise of authority under

section 7508A(a).

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

June 1, 2026

Bulletin No. 2026–23

ACTION ON DECISION

Subject: Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court).

Issue: Whether the originally enacted version of 26 U.S.C. § 7508A(d)1 provided for an automatic and mandatory 60-day postponement of certain tax-related deadlines for all taxpayers affected by the federally declared disaster for the COVID-19 pandemic,

beginning January 20, 2020.

Discussion: Under section 7508A(a), the Secretary is authorized to postpone certain deadlines for up to one year for taxpayers

determined to be affected by a federally declared disaster. The Secretary has discretion to determine (1) who is an affected taxpayer;

(2) which deadlines should be postponed; and (3) how long the postponement should last (though no longer than one year). A federally declared disaster includes both a major disaster declared under section 401 of the Stafford Act ( 42 U.S.C. § 5121, et seq.) and

an emergency declared under section 501 of the Stafford Act, but there is no distinction between these types of events for section

7508A(a) purposes. Treas. Reg. § 1.165-11(b)(1). The Federal Emergency Management Agency (FEMA) determines when a federally

declared disaster exists and whether Public Assistance and/or Individual Assistance will be given, then issues the disaster declaration,

signed by the President. Once the disaster declaration is issued, the Secretary is authorized to exercise discretion to postpone tax-related deadlines for affected taxpayers. The Secretary may postpone deadlines for the acts listed in section 7508(a)(1), including filing

returns, paying taxes, filing petitions with the U.S. Tax Court, certain government acts, and any other act required or permitted under

the Internal Revenue Code specified by the Secretary.2 When an affected taxpayer is required to perform a tax-related act by a due

date that falls within the postponement period, the affected taxpayer is eligible for postponement of the time to perform the act until

the last day of the period determined by the Secretary. Treas. Reg. § 301.7508A-1(b)(2). The Secretary may also disregard the disaster

postponement period when calculating the amount of any interest, penalty, additional amount, or addition to the tax owed related to

due dates that fall within the postponement period, or when calculating the amount of any credit or refund. I.R.C. § 7508A(a)(2)-(3).

In 2019, Congress added paragraph (d) to section 7508A.3 Paragraph (d) gave taxpayers a mandatory minimum 60-day postponement

of certain tax-related deadlines, effective for disasters declared after December 20, 2019. The text of paragraph (d) specified that

mandatory relief was to be applied “in the same manner as” discretionary relief under section 7508A(a), but it did not identify which

deadlines (i.e., taxpayer acts, government acts, or both) should be postponed. Paragraph (d) also failed to explain how to calculate the

mandatory 60-day period if there is no incident date of the disaster specified in the declaration, whether mandatory relief can run longer than the year-long limit for discretionary relief under section 7508A(a), and whether mandatory relief applies to every federally

declared disaster. It is this version of the statute that was in effect at the time of the issuance of the COVID-19 disaster declarations

discussed below.

To address these ambiguities in the statutory language, the Treasury Department published final regulations in June 2021, effective

for disasters declared after December 20, 2019. Treas. Reg. §§ 301.7508A-1(g) and (h) specify that to apply section 7508A(d) “in

the same manner” as section 7508A(a), the Secretary must first exercise discretion before the mandatory 60-day postponement takes

effect. The deadlines postponed under the mandatory 60-day postponement are the same deadlines determined by the Secretary in

the grant of discretionary relief under section 7508A(a). The mandatory relief postponement period runs concurrently with the discretionary relief period determined by the Secretary, which cannot last longer than one year. Finally, mandatory relief under section

7508A(d) does not apply when the disaster declaration fails to specify an incident date of the disaster.

In November 2021, Congress amended paragraph (d), effective for disasters declared after November 15, 2021, replacing the “in the

same manner as” language, which tied the application of mandatory relief to discretionary relief, with a statement that the period of

mandatory relief “shall be disregarded” in determining the timeliness of the specified acts. See Infrastructure Investment and Jobs

Act, Pub. L. No. 117-58, § 80501, 135 Stat. 429, 1335 (2021). The amended version of section 7508A(d) also clarified that only taxpayer acts (not government acts) are to be mandatorily postponed. It also explained how to calculate the 60-day postponement period

if there is no incident date of the disaster stated in the disaster declaration and specified that mandatory relief applies only to major

disasters in response to which Individual Assistance is provided by FEMA (i.e., not to every federally declared disaster).

On March 13, 2020, the President issued a nationwide emergency declaration without an incident date in response to the COVID-19

pandemic. Pursuant to the emergency declaration, the Secretary then issued a series of notices granting discretionary relief under

section 7508A(a) and citing the President’s nationwide emergency declaration. See, e.g., Notice 2020-23, 2020-18 I.R.B. 742, which

All statutory references hereafter are made to 26 U.S.C. (I.R.C.) unless otherwise specified.

See also Treas. Reg. § 301.7508A-1(c).

See Further Consolidated Appropriations Act, 2020, Pub. L. No. 116-94, div. Q, § 205, 133 Stat. 2534, 3245–46 (2019).

June 1, 2026

1556

Bulletin No. 2026–23

postponed, among other things, the filing deadline for most federal income tax returns from April 15, 2020, until July 15, 2020. On

March 31, 2020, the President issued a major disaster declaration for COVID-19 for Ohio, identifying the disaster as “beginning

on January 20, 2020, and continuing.”4 The IRS did not provide any discretionary or mandatory relief based on this or any other

state-specific major disaster declaration.

In Abdo v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court), the IRS issued a notice of deficiency to petitioners

at their last known address in Ohio on December 2, 2019. Their deadline to file a petition with the Tax Court was March 2, 2020, but

petitioners didn’t mail their petition to the court until March 17, 2020. The Commissioner moved to dismiss the Abdo petition for

untimeliness, but petitioners argued that the Ohio major disaster declaration entitled them to a mandatory 60-day postponement of

time to file a petition from January 20, 2020, to March 20, 2020, rendering timely the petition they filed on March 17, 2020.

The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that

section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incorporated all of the acts referenced by section 7508A(a), from the earliest incident date specified in the Ohio declaration, and lasting

for at least 60 days until March 20, 2020. Based upon this reasoning, the Tax Court determined petitioners’ petition was timely filed.

In so holding, the Tax Court invalidated Treas. Reg. §§ 301.7508A(g)(1) and (2), which limited non-pension-related time-sensitive

acts postponed for the mandatory 60-day period only to acts determined to be postponed by the Secretary’s exercise of discretionary

authority under section 7508A(a).5 The Tax Court did not express a view on what the outer limits of the mandatory postponement

period could be when a disaster declaration omits an ending date or is extended. Abdo, 162 T.C. at 169 n.13. The IRS disagrees with

the Tax Court’s holding that the phrase “in the same manner” in former section 7508A(d) is unambiguous and will continue to defend

its interpretation of that provision in the Treasury Regulations, which required the Secretary to first specify whether, and for what

acts, discretionary relief would be granted before section 7508A(d)’s mandatory minimum postponement period of 60 days would

be triggered.

Recommendation: Acquiescence only to the Tax Court’s holding that the COVID-19 disaster declarations created a mandatory

60-day postponement period from January 20, 2020, to March 20, 2020. The IRS does not acquiesce to the reasoning of the opinion,

the invalidation of the relevant portions of the regulation, or an interpretation that would result in any further postponement beyond

the 60 days provided by the Tax Court in Abdo.

________________________________

Scott Panitz

Attorney, Branch 6

(Procedure & Administration)

Reviewer:

ACK

MEA

Approved:

KENNETH KIES

Chief Counsel (acting)

Internal Revenue Service

By: ________________________________

Paul T. Butler

Associate Chief Counsel

Procedure & Administration

Identical major disaster declarations were issued for all U.S. states and territories.

The IRS disagrees with the partial invalidation of the regulations, but notes that Treas. Reg. §§ 301.7508A(g)(1) and (2) were rendered obsolete following the enactment of the November

2021 amendments to section 7508A(d).

Bulletin No. 2026–23

1557

June 1, 2026

Part I

26 CFR 1.6050K-1: Returns relating to sales or

exchanges of certain partnership interests.

T.D. 10048

DEPARTMENT OF THE

TREASURY

Internal Revenue Service

26 CFR Part 1

Returns Relating to Sales

or Exchanges of Certain

Partnership Interests

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains

final regulations modifying information

reporting obligations with respect to sales

or exchanges of certain interests in partnerships owning inventory or unrealized

receivables.

DATES: Effective date: These regulations are effective on May 20, 2026.

Applicability date: For dates of applicability, see §1.6050K-1(h).

FOR FURTHER INFORMATION

CONTACT: Benjamin Weaver, (202)

317-6850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Authority

This document contains final regulations amending the Income Tax Regulations (26 CFR part 1) under section 6050K

of the Internal Revenue Code (Code) by

removing §1.6050K-1(c)(2).

Section 6050K(a) provides that, except

as provided in regulations prescribed by

the Secretary of the Treasury or the Secretary’s delegate (Secretary), a partnership is required to file a return if there is

an exchange described in section 751(a)

of the Code of any interest in the partnership during any calendar year. Section

June 1, 2026

6050K(a) also contains express delegations of authority for the Secretary to promulgate regulations prescribing the information required to be disclosed on such

partnership returns, the manner in which

such returns are made, and the due date of

such returns.

Section 6031(a) of the Code provides

an express grant of authority for the Secretary to prescribe in forms or regulations

partnership reporting information required

“for the purpose of carrying out the provisions of subtitle A.”

Section 7805(a) of the Code authorizes

the Secretary to “prescribe all needful

rules and regulations for the enforcement

of [the Code], including all rules and regulations as may be necessary by reason of

any alteration of law in relation to internal

revenue.”

Background

I. Statutory and Regulatory Background

Section 741 of the Code provides that

gain or loss recognized by a transferor

partner upon sale or exchange of a partnership interest is considered as gain or

loss from the sale or exchange of a capital asset, except as provided in section

751. Section 751(a) provides that the

amount of any money, or the fair market value of any property, received by a

transferor partner in exchange for all or a

part of the transferor partner’s interest in

the partnership attributable to (1) unrealized receivables of the partnership, or (2)

inventory items of the partnership, will

be considered as an amount realized from

the sale or exchange of property other

than a capital asset. Section 1.6050K1(a)(4)(i) refers to a sale or exchange to

which section 751(a) applies as a “section 751(a) exchange.”

Section 6050K(a) requires a partnership to file a return if there is a section

751(a) exchange of any interest in the

partnership during any calendar year. Section 6050K(a) further provides that the

return must state the name and address of

the transferee and transferor in the section

751(a) exchange and such other information as the Secretary may by regulations

prescribe.

1558

Section 1.6050K-1(a)(1) generally

requires a partnership to make a separate

return using Form 8308, Report of a Sale

or Exchange of Certain Partnership Interests, with respect to each section 751(a)

exchange. Section 1.6050K-1(b) requires

the Form 8308 to include the following

information: (1) the names, addresses,

and taxpayer identification numbers of the

transferee and transferor in the exchange

and of the partnership filing the return;

(2) the date of the exchange; and (3) such

other information as may be required

by Form 8308 or its instructions. Section 1.6050K-1(f)(1) requires a partnership to file Form 8308 as an attachment to

its Form 1065, U.S. Return of Partnership

Income, for the partnership’s taxable year

that includes the last day of the calendar

year in which the section 751(a) exchange

took place.

Section 6050K(b) requires a partnership to provide certain information to

transferors and transferees that are parties

to a section 751(a) exchange on or before

January 31 of the year following the calendar year of the section 751(a) exchange.

Among other things, the information provided to each transferor and transferee

must include the information required

to be shown on the partnership’s return

under section 6050K(a) with respect to

such person.

Section 6050K(c)(1) provides that the

transferor of the partnership interest must

notify the partnership of any exchange

described in section 6050K(a). Under

section 6050K(c)(2), a partnership is

not required to make a return under section 6050K with respect to any exchange

until the partnership is notified of such

exchange.

Section 1.6050K-1(c)(1) clarifies that

each partnership that is required to file a

Form 8308 must furnish a statement to

the transferor and transferee by the later

of (1) January 31 of the year following

the calendar year in which the section

751(a) exchange occurs, or (2) 30 days

after the partnership receives notice of

the exchange as specified under section

6050K(c) and §1.6050K-1(e). Prior to its

modification by these final regulations,

§1.6050K-1(c)(1) generally required a

partnership to use a copy of the com-

Bulletin No. 2026–23

pleted Form 8308 as the required statement.

In addition, prior to its removal by

these final regulations, §1.6050K-1(c)(2)

required a partnership to furnish to a transferor partner the information necessary for

the transferor to make the transferor partner’s required statement in §1.751-1(a)

(3). Section 1.751-1(a)(3) requires a transferor partner in a section 751(a) exchange

to submit with the transferor partner’s

income tax return for the taxable year in

which the sale or exchange occurs a statement separately stating the date of the sale

or exchange, the amount of any gain or

loss attributable to section 751 property,

and the amount of any gain or loss attributable to capital gain or loss on the sale

of the partnership interest. Consistent with

§1.6050K-1(c)(2), Part IV of Form 8308

requires a partnership to report, among

other items, the partnership’s gain or loss

from a deemed sale under section 751

and the transferor partner’s share of such

amount.

The Department of the Treasury (Treasury Department) and the IRS received

comments from stakeholders that many

partnerships are unable to furnish the

information required in Part IV of the

Form 8308 to transferors and transferees

by the January 31 due date prescribed by

§1.6050K-1(c)(1) because, in many cases,

partnerships do not have all the information required by Part IV of the Form 8308

by January 31 of the year following the

calendar year in which the section 751(a)

exchange occurred.

II. Proposed Regulations

In response to those comments, on

August 19, 2025, the Treasury Department and the IRS published a notice of

proposed rulemaking (REG-108822-25)

in the Federal Register (90 FR 40269)

to propose the removal of §1.6050K1(c)(2) (proposed regulations). The proposed regulations also proposed to modify §1.6050K-1(c)(1) by removing the

reference to a “completed copy of Form

8308” and replacing it with a reference to

“a copy of Form 8308 filled out in accordance with the instructions to the form.”

In addition, the preamble to the proposed

regulations explained that the Treasury

Department and the IRS would update

Bulletin No. 2026–23

the instructions for Form 8308 to provide

that only the information in Parts I, II, and

III is required by the due dates of section

6050K. The instructions to Form 8308

were updated on November 5, 2025.

As a result of the proposed changes to

§1.6050K-1 and the associated changes in

the instructions to Form 8308, a partnership would be required to furnish the information reported on only Parts I, II, and III

of Form 8308, or a statement that includes

the same information, to the transferor and

transferee in a section 751(a) exchange

by the later of (1) January 31 of the year

following the calendar year in which the

section 751(a) exchange occurred, or (2)

30 days after the partnership has received

notice of the exchange as specified under

section 6050K and §1.6050K-1.

Further, the preamble to the proposed

regulations explained that the Treasury

Department and the IRS would update

the Instructions for Form 8308 to make

clear that a partnership must file a completed Form 8308, including Part IV,

as an attachment to its Form 1065. The

update to the Form 8308 instructions

reflects this. Accordingly, and pursuant to

§1.6031(a)-1(a)(2), which provides that a

partnership return must contain the information required by the prescribed form

and the accompanying instructions, a partnership would be required to file the completed Form 8308, including Part IV, as an

attachment to its Form 1065, for the taxable year of the partnership that includes

the last day of the calendar year in which

the section 751(a) exchange took place.

Thus, the requirement that a partnership

file a completed Form 8308, including

Part IV, as an attachment to its Form 1065

would remain unchanged by the proposed

regulations.

The preamble to the proposed regulations further explained that, pursuant to

§1.6031(b)-1T(a)(3), the partnership will

also continue to be required to report the

information required of the transferor in

§1.751-1(a)(3) to the transferor (including

the information required in Part IV of the

Form 8308), in the Schedule K-1 (Form

1065), Partner’s Share of Income, Deductions, Credits, etc., issued to the transferor

partner as provided by the Form and Instructions to the Schedule K-1 (Form 1065).

Finally, the proposed regulations would

modify §1.6050K-1(c)(1)(i) to clarify that

1559

the partnership will be providing to the

IRS the information included on a substitute statement furnished in lieu of a Form

8308 under §1.6050K-1(c)(1).

The preamble to the proposed regulations stated that §1.6050K-1(c)(2) was

proposed to be removed on the date the

regulations are published as final regulations in the Federal Register. The amendment to §1.6050K-1(c)(1)(i) was proposed

to apply to returns filed for taxable years

ending on or after the date the regulations

are published as final regulations in the

Federal Register. The preamble to the

proposed regulations stated that a partnership may rely on the proposed regulations,

and the description of the anticipated

changes to the instructions to Form 8308

contained in the preamble to the proposed

regulations, with respect to section 751(a)

exchanges occurring on or after January 1,

2025, and before the date the regulations

are published as final regulations in the

Federal Register.

Summary of Comments and

Explanation of Revisions

The Treasury Department and IRS did

not receive any comments pertaining to

the proposed regulations, and no public

hearing was requested or held. Accordingly, these final regulations adopt the

proposed regulations without change.

Special Analyses

I. Regulatory Planning and Review

These final regulations are not subject

to review under section 6(b) of Executive

Order 12866 pursuant to the Memorandum of Agreement (July 4, 2025) between

the Treasury Department and the Office of

Management and Budget (OMB) regarding review of tax regulations. Therefore,

a regulatory impact assessment is not

required.

The Executive Order 14192 designation for this rule is expected to be deregulatory.

II. Paperwork Reduction Act

The Paperwork Reduction Act of 1995

(44 U.S.C. 3501-3520) generally requires

that a Federal agency obtain the approval

June 1, 2026

of the OMB before collecting information

from the public, whether such collection

of information is mandatory, voluntary,

or required to obtain or retain a benefit.

An agency may not conduct or sponsor,

and a person is not required to respond

to, a collection of information unless the

collection of information displays a valid

control number. These final regulations do

not impose a new collection of information or modify an existing collection of

information.

III. Regulatory Flexibility Act

It is hereby certified that the final regulations will not have a significant economic impact on a substantial number of

small entities pursuant to the Regulatory

Flexibility Act (5 U.S.C. chapter 6). These

final regulations affect partnerships for

which there is a section 751(a) exchange

(as defined in §1.6050K-1(a)(4)(i)). These

final regulations will likely affect a substantial number of small entities organized

as partnerships for Federal tax purposes,

but the impact of the final regulations is

limited because the final regulations delay

the date by which partnerships must provide transferors of interests in the partnership the information necessary for

the transferor to make the transferor’s

required statement under §1.751-1(a)(3).

This delay benefits the partnerships by

providing additional time to furnish the

information but will not have a significant

economic impact. Accordingly, a regulatory flexibility analysis under the Regulatory Flexibility Act is not required.

IV. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandate

Reform Act of 1995 (UMRA) requires

that agencies assess anticipated costs and

benefits and take certain other actions

before issuing a final rule that includes

any Federal mandate that may result in

expenditures in any one year by a State,

local, or Tribal government, in the aggregate, or by the private sector, of $100

million (updated annually for inflation).

These final regulations do not include any

Federal mandate that may result in expenditures by State, local, or Tribal governments or by the private sector in excess of

that threshold.

June 1, 2026

V. Executive Order 13132: Federalism

PART 1--INCOME TAXES

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

compliance costs on State and local governments, and is not required by statute,

or preempts State law, unless the agency

meets the consultation and funding

requirements of section 6 of the Executive

order. These final regulations do not have

federalism implications and do not impose

substantial, direct compliance costs on

State and local governments or preempt

State law within the meaning of the Executive order.

Paragraph 1. The authority citation

for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

*****

Par. 2. Section 1.6050K-1 is amended

by:

1. Adding a heading for paragraph (c);

2. Revising the paragraph heading and

introductory text of paragraph (c)(1);

3. Revising paragraph (c)(1)(i);

4. Removing paragraph (c)(2) and

redesignating paragraph (c)(3) as new

paragraph (c)(2); and

5. Revising paragraph (h).

The addition and revisions read as follows:

VI. Small Business Administration

Pursuant to section 7805(f) of the Code,

the proposed rule preceding these final

regulations was submitted to the Chief

Counsel for Advocacy of the Small Business Administration for comment on its

impact on small business. No comments

were received from the Chief Counsel for

Advocacy of the Small Business Administration.

VII. Congressional Review Act

Pursuant to the Congressional Review

Act (5 U.S.C. 801 et seq.), the Office of

Information and Regulatory Affairs designated this rule as not a “major rule,” as

defined by 5 U.S.C. 804(2).

Drafting Information

The principal author of these final

regulations is the Office of Associate

Chief Counsel (Passthroughs, Trusts, and

Estates). However, other personnel from

the Treasury Department and the IRS participated in their development.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Amendments to the Regulations

Accordingly, the Treasury Department and IRS amend 26 CFR part 1 as

follows:

1560

§1.6050K-1 Returns relating to sales

or exchanges of certain partnership

interests.

*****

Every partnership required to file a return

under paragraph (a) of this section must

furnish to each person whose name is

required to be set forth in such return a

written statement on or before January

31 of the calendar year following the calendar year in which the section 751(a)

exchange occurred to which the return

under paragraph (a) relates (or, if later,

30 days after the partnership is notified

of the exchange as defined in paragraph

(e) of this section). The partnership must

use a copy of the Form 8308, filled out in

accordance with the instructions accompanying the form, as a statement unless

the Form 8308 contains information with

respect to more than one section 751(a)

exchange (see paragraph (a)(3) of this

section). If the partnership does not use

a copy of Form 8308 as a statement, the

statement shall include the information

required to be shown on Form 8308 with

respect to the section 751(a) exchange to

which the person to whom the statement

is furnished is a party. In addition, it shall

state that—

(i) The information shown on the statement will be supplied to the Internal Revenue Service,

*****

Bulletin No. 2026–23

(h) Applicability date. Paragraphs (c)

(1) introductory text and (c)(1)(i) of this

section apply to returns filed for taxable

years ending on or after May 20, 2026.

Paragraph (c)(2) of this section applies

to returns filed on or after November 30,

2020. Paragraph (d)(3) of this section

Bulletin No. 2026–23

applies to transfers that occur on or after

November 30, 2020.

Frank J. Bisignano,

Chief Executive Officer.

Approved: April 29, 2026.

1561

Kenneth J. Kies,

Assistant Secretary of the Treasury

(Tax Policy).

(Filed by the Office of the Federal Register May 19,

2026, 8:45 a.m., and published in the issue of the

Federal Register for May 20, 2026, 91 FR 29362.)

June 1, 2026

Part III

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

under § 414(y)) pursuant to § 412. Section

430(h)(2) specifies the interest rates that

must be used to determine a plan’s target

normal cost and funding target. Under

this provision, present value is generally

determined using three 24-month average

interest rates (“segment rates”), each of

which applies to cash flows during specified periods. To the extent provided under

§ 430(h)(2)(C)(iv), these segment rates

are adjusted by the applicable percentage

of the 25-year average segment rates for

the period ending September 30 of the

year preceding the calendar year in which

the plan year begins.1 However, an election may be made under § 430(h)(2)(D)

(ii) to use the monthly yield curve in place

of the segment rates.

Section 1.430(h)(2)-1(d) provides

rules for determining the monthly corporate bond yield curve, and § 1.430(h)

(2)-1(c) provides rules for determining

the 24-month average corporate bond

segment rates used to compute the target

normal cost and the funding target. Consistent with the methodology specified in

§ 1.430(h)(2)-1(d), the monthly corporate

bond yield curve derived from April 2026

Notice 2026-31

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the

Internal Revenue Code. In addition, this

notice provides guidance as to the interest rate on 30-year Treasury securities

under § 417(e)(3)(A)(ii)(II) as in effect for

plan years beginning before 2008 and the

30-year Treasury weighted average rate

under § 431(c)(6)(E)(ii)(I).

YIELD CURVE AND SEGMENT

RATES

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC plans

Applicable Month

May 2026

data is in Table 2026-4 at the end of this

notice. The spot first, second, and third

segment rates for the month of April 2026

are, respectively, 4.27, 5.34, and 6.22.

The 24-month average segment rates

determined under § 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant to

§ 430(h)(2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. Those percentages are

95% and 105% for plan years beginning

in 2025 and 2026. For this purpose, any

25-year average segment rate that is less

than 5% is deemed to be 5%. The 25-year

average segment rates for plan years

beginning in 2025 and 2026 were published in Notice 2024-67, 2024-41 I.R.B.

726 and Notice 2025-47, 2025-40 I.R.B.

441, respectively.

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate

bond segment rates applicable for May

2026 without adjustment for the 25-year

average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment

First Segment

Second Segment

Third Segment

4.42

5.26

5.87

The adjusted 24-month average segment rates set forth in the chart below

reflect § 430(h)(2)(C)(iv) of the Code. The

24-month averages applicable for May

2026, adjusted to be within the applicable

minimum and maximum percentages of

the corresponding 25-year average segment rates in accordance with § 430(h)(2)

(C)(iv), are as follows:

Adjusted 24-Month Average Segment Rates

For Plan Years

Beginning In

Applicable Month

First Segment

Second Segment

Third Segment

2025

May 2026

4.75

5.26

5.87

2026

May 2026

4.75

5.25

5.87

30-YEAR TREASURY SECURITIES

INTEREST RATES

Section 431 specifies the minimum

funding requirements that apply to multi-

employer plans pursuant to § 412. Section

431(c)(6)(B) specifies a minimum amount

for the full-funding limitation described in

§ 431(c)(6)(A), based on the plan’s current

liability. Section 431(c)(6)(E)(ii)(I) pro-

vides that the interest rate used to calculate

current liability for this purpose must be

no more than 5 percent above and no more

than 10 percent below the weighted average of the rates of interest on 30-year Trea-

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount

of the full funding limitation under § 433(c)(7)(C)).

June 1, 2026

1562

Bulletin No. 2026–23

sury securities during the four-year period

ending on the last day before the beginning

of the plan year. Notice 88-73, 1988-2 C.B.

383, provides guidelines for determining

the weighted average interest rate. The rate

of interest on 30-year Treasury securities

for April 2026 is 4.91 percent. The Service

determined this rate as the average of the

daily determinations of yield on the 30-year

Treasury bond maturing in February 2056.

For plan years beginning in May 2026, the

weighted average of the rates of interest on

30-year Treasury securities and the permissible range of rates used to calculate current

liability are as follows:

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

May 2026

4.50

4.05 to 4.72

under § 417(e)(3)(D) are segment rates

computed without regard to a 24-month

average. Section 1.417(e)-1(d)(3) provides guidelines for determining the min-

imum present value segment rates. Pursuant to that section, the minimum present

value segment rates determined for April

2026 are as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

April 2026

Minimum Present Value Segment Rates

First Segment

Second Segment

4.27

5.34

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2026–23

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

1563

Third Segment

6.22

of this guidance. For further information

regarding this notice, contact Mr. Morgan

at 202-317-6700 or Tony Montanaro at

626-927-1475 (not toll-free calls).

June 1, 2026

Table 2026-4

Monthly Yield Curve for April 2026

Derived from April 2026 Data

Maturity

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

7.5

8.0

8.5

9.0

9.5

10.0

10.5

11.0

11.5

12.0

12.5

13.0

13.5

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

18.5

19.0

19.5

20.0

Yield

4.00

4.08

4.16

4.22

4.27

4.31

4.35

4.39

4.44

4.49

4.55

4.61

4.68

4.74

4.81

4.88

4.95

5.01

5.07

5.13

5.19

5.25

5.30

5.35

5.40

5.45

5.49

5.53

5.57

5.61

5.64

5.67

5.70

5.73

5.76

5.79

5.81

5.83

5.86

5.88

June 1, 2026

Maturity

20.5

21.0

21.5

22.0

22.5

23.0

23.5

24.0

24.5

25.0

25.5

26.0

26.5

27.0

27.5

28.0

28.5

29.0

29.5

30.0

30.5

31.0

31.5

32.0

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

38.0

38.5

39.0

39.5

40.0

Yield

5.90

5.91

5.93

5.95

5.96

5.98

5.99

6.00

6.01

6.03

6.04

6.05

6.06

6.07

6.08

6.09

6.10

6.11

6.12

6.13

6.14

6.15

6.16

6.17

6.18

6.19

6.20

6.21

6.22

6.23

6.24

6.25

6.26

Maturity

40.5

41.0

41.5

42.0

42.5

43.0

43.5

44.0

44.5

45.0

45.5

46.0

46.5

47.0

47.5

48.0

48.5

49.0

49.5

50.0

50.5

51.0

51.5

52.0

52.5

53.0

53.5

54.0

54.5

55.0

55.5

56.0

56.5

57.0

57.5

58.0

58.5

59.0

59.5

60.0

Yield

6.26

6.27

6.28

6.29

6.30

6.31

6.32

6.33

6.34

6.35

6.36

6.37

6.38

6.39

1564

Maturity

60.5

61.0

61.5

62.0

62.5

63.0

63.5

64.0

64.5

65.0

65.5

66.0

66.5

67.0

67.5

68.0

68.5

69.0

69.5

70.0

70.5

71.0

71.5

72.0

72.5

73.0

73.5

74.0

74.5

75.0

75.5

76.0

76.5

77.0

77.5

78.0

78.5

79.0

79.5

80.0

Yield

6.40

6.41

6.42

6.43

6.44

6.45

6.46

Maturity

80.5

81.0

81.5

82.0

82.5

83.0

83.5

84.0

84.5

85.0

85.5

86.0

86.5

87.0

87.5

88.0

88.5

89.0

89.5

90.0

90.5

91.0

91.5

92.0

92.5

93.0

93.5

94.0

94.5

95.0

95.5

96.0

96.5

97.0

97.5

98.0

98.5

99.0

99.5

100.0

Yield

6.46

6.47

6.48

6.49

6.50

Bulletin No. 2026–23

2026 Cumulative List

of Changes in Plan

Qualification Requirements

for Defined Benefit

Qualified Pre-approved

Plans

Notice 2026-34

I. PURPOSE

This notice sets forth the 2026 Cumulative List of Changes in Plan Qualification

Requirements for Defined Benefit Qualified Pre-approved Plans (2026 Cumulative List). The 2026 Cumulative List will

assist providers applying to the Internal

Revenue Service (IRS) for opinion letters

for the fourth remedial amendment cycle

for defined benefit qualified pre-approved

plans (Cycle 4) under the IRS’s pre-approved plan program. Cycle 4 began on

April 1, 2025. The Cycle 4 submission

period begins on August 1, 2026, and

ends on July 31, 2027. The 2026 Cumulative List identifies recent changes in the

qualification requirements of the Internal

Revenue Code (Code) that were not taken

into account during the first three remedial amendment cycles for defined benefit qualified pre-approved plans and that

will be taken into account by the IRS with

respect to the form of a plan submitted to

the IRS for Cycle 4.

II. BACKGROUND

Under Rev. Proc. 2023-37, 2023-51

IRB 1491, every pre-approved plan has

a recurring remedial amendment cycle,

and a provider of a pre-approved plan

may apply for a new opinion letter for

the plan for each remedial amendment

cycle. Further, defined contribution qualified pre-approved plans, defined benefit

qualified pre-approved plans, and sec-

tion 403(b) pre-approved plans all have

separate remedial amendment cycles. Part

III of Rev. Proc. 2023-37 sets forth the

procedures for a provider to apply for an

opinion letter for a pre-approved plan, as

well as the scope of reliance provided by

an opinion letter to adopting employers of

a provider’s pre-approved plan.

Pursuant to section 17 of Rev. Proc.

2023-37, the IRS publishes a cumulative

list for each remedial amendment cycle

to identify the recent changes in the qualification requirements that will be taken

into account with respect to the form of

a pre-approved plan submitted to the IRS

for that remedial amendment cycle.1 A

change in the qualification requirements

includes a statutory change or a change

in the requirements provided in regulations or other guidance published in the

Internal Revenue Bulletin, without regard

to whether the change is required to be

reflected in plan terms or relates to an

optional provision that a provider could

choose to reflect in plan terms as a discretionary amendment.

III. APPLICATION OF THE 2026

CUMULATIVE LIST

In section IV of this notice, the 2026

Cumulative List sets forth specific items

the IRS has identified for review in determining whether the form of a defined benefit qualified pre-approved plan that has

been submitted to the IRS for a Cycle 4

opinion letter has been properly updated

since the plan was submitted for a Cycle 3

opinion letter.2

Generally, the IRS will consider only

the items on the 2026 Cumulative List

in determining whether to issue a Cycle

4 opinion letter with respect to a defined

benefit qualified pre-approved plan, and

providers of pre-approved plans should not

include in plan documents submitted with

their Cycle 4 opinion letter applications

terms reflecting the provisions of legisla-

tion enacted or guidance issued after this

notice is issued. However, if a plan has not

been previously reviewed and is submitted for Cycle 4 (or has been amended with

respect to previously approved language),

the IRS will also review the plan for items

on earlier Cumulative Lists,3 as well as for

any other applicable qualification requirements that were considered by the IRS in

issuing opinion letters prior to the implementation of Cumulative Lists.

The list of changes in section IV of this

notice does not extend the deadline by

which a plan must be amended to comply with any change in the qualification

requirements applicable to the plan. The

general deadline for timely adoption of

an interim or discretionary amendment is

provided in section 7 of Rev. Proc. 202337. However, Q&A J-1 of Notice 20242, 2024-2 IRB 316, provides additional

guidance with respect to the deadlines

for interim or discretionary amendments

adopted to reflect applicable provisions

of Division O of the Further Consolidated

Appropriations Act, 2020, Pub. L. 116-94,

133 Stat. 2534 (FCAA), known as the Setting Every Community Up for Retirement

Enhancement Act of 2019 (SECURE Act),

section 104 of Division M of the FCAA,

known as the Bipartisan American Miners

Act of 2019 (Miners Act), section 2202 or

2203 of the Coronavirus Aid, Relief, and

Economic Security Act, Pub. L. 116-136,

134 Stat. 281 (2020) (CARES Act), as

modified by section 280 of the COVID-related Tax Relief Act of 2020, which was

enacted as Subtitle B, Title II, Division N,

of the Consolidated Appropriations Act,

2021, Pub. L. 116-260, 134 Stat. 1182

(2020) (CAA 2021), section 302 of Title

III of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act),

enacted as Division EE of CAA 2021, or

Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat.

4459 (2022), known as the SECURE 2.0

Act of 2022 (SECURE 2.0 Act).

In order to be qualified, a defined benefit pre-approved plan must comply in operation with all applicable qualification requirements, not only those on the 2026 Cumulative List. To assist plan

providers in achieving operational compliance, the IRS provides an Operational Compliance List on its website that is updated periodically to identify changes in qualification requirements

that are effective during a calendar year. For the current Operational Compliance List, see https://www.irs.gov/retirement-plans/operational-compliance-list.

Consistent with previous Cumulative Lists, the 2026 Cumulative List does not include routine, ministerial guidance (such as guidance that is typically issued annually to announce a costof-living adjustment to a qualified plan contribution limit).

For the items on earlier Cumulative Lists for defined benefit qualified pre-approved plans, see the 2020 Cumulative List, Notice 2020-14, 2020-13 IRB 555, and the 2012 Cumulative List,

Notice 2012-76, 2012-52 IRB 775.

Bulletin No. 2026–23

1565

June 1, 2026

IV. 2026 CUMULATIVE LIST OF

CHANGES IN PLAN QUALIFICATION

REQUIREMENTS FOR DEFINED

BENEFIT QUALIFIED PREAPPROVED PLANS

•

Section 401(a):

Required Minimum Distributions

(Section 401(a)(9))

i. Required beginning date

• Section 114 of the SECURE

Act amended section 401(a)(9)

(C)(i)(I) of the Code to increase

the age with respect to which

the required beginning date for

required minimum distributions

(RMDs) is determined from age

70½ to age 72 for employees

born on or after July 1, 1949, but

before January 1, 1951.

• Section 107 of the SECURE

2.0 Act amended section 401(a)

(9)(C) of the Code to increase

the age with respect to which

the required beginning date for

RMDs is determined from age

72 to age 73, for employees born

on or after January 1, 1951.4

ii. Miscellaneous

• Section 401 of the SECURE Act

amended section 401(a)(9) of the

Code to provide new RMD rules

for designated beneficiaries.

• Final regulations under section

401(a)(9) of the Code that were

published on July 19, 2024 (89

FR 58886), provide guidance

relating to RMDs from defined

benefit plans that reflects the

amendments made to section

401(a)(9) by sections 114 and

401 of the SECURE Act and by

section 107 and other sections

of the SECURE 2.0 Act. These

regulations apply for purposes of

determining required minimum

distributions for calendar years

beginning on or after January 1,

2025.5

Notice 2023-54, 2023-31 IRB

383, provides relief with respect

to certain required minimum distributions for 2023.

Certain Involuntary Distributions

(Code Sections 401(a)(31)(B) and

411(a)(11))

• Section 304 of the SECURE 2.0

Act permits a plan to increase its

involuntary cashout limit from

$5,000 to $7,000.

Distributions During Working Retirement (Code Section 401(a)(36))

• Section 104 of the Miners Act

amended section 401(a)(36) of

the Code to lower the minimum

age at which a pension plan

may make a distribution to an

employee who is not separated

from employment at the time of

the distribution. For plan years

beginning after December 31,

2019, the minimum age is lowered from age 62 to age 59½.

• Notice 2020-68, 2020-38 IRB

567, provides guidance with

respect to section 104 of the Miners Act.

Forfeitures

• Proposed regulations under section 401 of the Code that were

published on February 27, 2023

(88 FR 12282), would provide

rules relating to the use of forfeitures in qualified retirement

plans. The proposed regulations

are proposed to apply for plan

years that begin on or after January 1, 2024, but, prior to the

applicability date of final regulations, taxpayers may rely on the

proposed regulations.

Witnessing of Spousal Consent

• Proposed regulations under section 401 of the Code that were

published on December 30, 2022

(87 FR 80501), would provide an

alternative to in-person witnessing of spousal consents required

to be witnessed by a notary public or a plan representative and

would clarify that certain special

rules for the use of an electronic

medium for participant elections

also apply to spousal consents.

The regulations are proposed

to apply beginning on the date

that is six months after the publication of final regulations, but,

prior to the applicability date of

final regulations, taxpayers may

rely on the proposed regulations.6

Modification of Nondiscrimination

Rules to Protect Older, Longer Service Participants (Sections 401(a)

(26) and 401(o))

• Section 205 of the SECURE Act

added section 401(a)(26)(I) to

the Code to treat certain closed

or frozen defined benefit plans

as satisfying the section 401(a)

(26) minimum participation

requirements. Section 205 of the

SECURE Act also added section

401(o) to the Code to provide

special nondiscrimination testing

relief for plan sponsors seeking

to protect certain participants in

a closed defined benefit plan. In

addition, section 401(o)(2) permits nondiscrimination testing

relief where a sponsor provides

certain “make-whole” contributions to a defined contribution

plan.

Section 401(b):

• Section 316 of the SECURE

2.0 Act amended section 401(b)

of the Code to provide that if

an employer amends a plan to

increase accrued benefits effective as of any date during the

immediately preceding plan

year, the amendment would not

otherwise cause the plan to fail

to meet any of the qualification

requirements, and the amendment is adopted before the time

Section 107 of the SECURE 2.0 Act includes a provision increasing the age with respect to which the required beginning date for RMDs is determined to age 75. This increase will not

affect the timing of RMDs until after the end of Cycle 4 for defined benefit qualified pre-approved plans. Accordingly, the IRS will not review plan documents submitted for Cycle 4 for that

provision.

Proposed regulations under section 401(a)(9) that were published on February 24, 2022 (87 FR 10504), would provide guidance relating to RMDs from defined benefit plans that reflects the

amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely

on a good faith, reasonable interpretation of the amendments made by sections 114 and 401 of the SECURE Act to which the final regulations relate. Compliance with the proposed regulations

is considered reliance on a good faith, reasonable interpretation of the amendments made by sections 114 and 401 of the SECURE Act to which the final regulations relate.

The IRS expects that most plans will not need to be amended to reflect these proposed regulations relating to the witnessing of spousal consent, as most plans will not include language that

contradicts these proposed regulations.

June 1, 2026

1566

Bulletin No. 2026–23

prescribed by law for filing the

return of the employer for the

taxable year (including extensions) that includes the effective

date of the amendment, then

the employer may elect to treat

the amendment as having been

adopted as of the last day of the

plan year in which it is effective.

Sections 402 and 402A:

• Section 41104 of the Bipartisan

Budget Act of 2018, Pub. L. 115123, 132 Stat. 64, added section

6343(f) of the Code to hold an

individual harmless in the case

of a wrongful levy upon an eligible retirement plan. The eligible

retirement plan may permit the

re-contribution of any property

or money returned to the individual as a result of the wrongful

levy, and such contribution will

be treated as a rollover under section 402(c) or section 402A(c)

(3), as applicable.

• Final regulations under section

402(c) that were published on

July 19, 2024, amend the rules

relating to eligible rollover distributions from defined benefit

plans. These regulations apply

for distributions on or after January 1, 2025.7

Section 402(l):

• Section 328 of the SECURE 2.0

Act amended section 402(l)(5)

(A) of the Code to permit governmental plans to make direct

distributions to certain eligible

retired public safety officers of

amounts necessary to pay for

qualified health insurance premiums.

Section 411:

Partial Terminations

• Section 209 of the Relief Act

provides temporary guidance

relating to partial plan terminations.8

Cash Balance Plans

• Under section 348 of the

SECURE 2.0 Act, a cash balance

plan that provides for pay credits to participants that increase

with a participant’s age or service and provides for a variable

interest crediting rate no longer risks violating the accrual

requirements of section 411(b)

(1) of the Code if that interest

crediting rate falls below a certain point. Section H of Notice

2024-2 provides guidance with

respect to the application of section 501 of the SECURE 2.0 Act

for amendments made pursuant

to section 348 of the SECURE

2.0 Act.

Sections 411 and 417:

• Final regulations under sections 411 and 417 of the Code

that were published on January

19, 2024 (89 FR 3552), provide

guidance relating to the minimum present value requirements

applicable to certain defined

benefit pension plans. The regulations provide guidance on

changes made by the Pension

Protection Act of 2006, Pub.

L. 109-280, 120 Stat. 780, to

the prescribed interest rate and

mortality table and other guidance, including rules regarding

the treatment of preretirement

mortality discounts and Social

Security level income options.

Section 414:

• Section 315 of the SECURE

2.0 Act amended section 414 of

the Code to eliminate automatic

attribution of ownership between

spouses with separate businesses in community property

states, and to modify the attribution rules regarding ownership

between parents and minor children, for purposes of applying

the rules relating to a controlled

group of corporations under section 414(b) or an affiliated service group under section 414(m).

• Final regulations that were published on December 30, 2024 (89

FR 106848) extend the partnership and trust attribution rules

to the determination of whether

a parent-subsidiary controlled

group exists under section 414(c)

(trades or businesses under common control). The change applies

to plan years beginning on or

after January 1, 2025.

8. Section 414(p):

• Section 339 of the SECURE

2.0 Act amended the definition

of “domestic relations order”

in section 414(p)(1)(B) of the

Code to include a domestic relations order issued pursuant to an

Indian tribal domestic relations

law.

9. Section 415(b):

• Section 119 of the SECURE 2.0

Act amended the limitations in

section 415(b) for certain participants in an eligible rural electric

cooperative plan.

10. Section 420:

• Section 606 of the SECURE 2.0

Act amended section 420 of the

Code to provide that a qualified

transfer of excess pension assets

of a defined benefit plan may be

made to a retiree medical account

or life insurance account within

the plan until December 31,

2032, rather than December 31,

2025. Section 420, as amended,

also provides a rule for de minimis transfers.

11. Sections 430 and 436:

• Section 3609 of the CARES Act

added section 414(y)(1)(D) to

the Code. Section 414(y)(1)(D)

provides that a cooperative and

small employer charity pension

plan (CSEC plan) is defined to

include a defined benefit plan

that, as of January 1, 2000, was

maintained by a tax-exempt

employer that met specific characteristics. A CSEC plan, as

defined in section 414(y), is not

permitted to include the benefit

restrictions of section 436.

Proposed regulations under section 402(c) that were published on February 24, 2022, would amend the rules relating to eligible rollover distributions from defined benefit plans. Under

the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the statutory amendments to which the final

regulations relate. Compliance with the proposed regulations is considered reliance on a good faith, reasonable interpretation of the statutory amendments to which the final regulations relate.

The IRS expects that most plans will not need to be amended to reflect section 209 of the Relief Act, as most plans will not include language contradicting it.

Bulletin No. 2026–23

1567

June 1, 2026

12. Disaster-related Rules:

• Section 202 of the Taxpayer Certainty and Disaster Tax Relief

Act of 2019, enacted as Division

Q of the FCAA, provides special

disaster-related rules for use of

retirement funds.

• Section 2202 of the CARES Act,

as modified by section 280 of Division N of the CAA 2021, provides

special rules for coronavirus-related distributions and plan loans

made to qualified individuals.

June 1, 2026

•

Notice 2020-50, 2020-28 IRB

35, provides guidance relating to

the application of section 2202

of the CARES Act for qualified

individuals and eligible retirement plans.

Section 302 of the Relief Act

provides special disaster-related

rules for use of retirement funds.

Section 331 of the SECURE 2.0

Act provides permanent special

rules governing plan distributions, recontributions, and loans

1568

to participants affected by qualified federally declared major

disasters.

V. DRAFTING INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

(Employee Benefits, Exempt Organizations, and Employment Taxes). For further

information regarding this notice, contact

Employee Plans at (513) 975-6319 (not a

toll-free number).

Bulletin No. 2026–23

Part IV

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2026-10

Table of Contents

The Internal Revenue Service has

revoked its determination that the organizations listed below qualify as organizations described in sections 501(c)(3) and

170(c)(2) of the Internal Revenue Code of

1986.

Name Of Organization

Societe Jacques Cartier Cercle No. 4

National Alliance on Mental Illness

Philantrepreneur

Les Cheneaux Pure Water Inc

Upper Room of Erie

Bulletin No. 2026–23

Generally, the IRS will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the IRS is not precluded from disallowing a deduction for

any contributions made after an organization ceases to qualify under section 170(c)

(2) if the organization has not timely filed

a suit for declaratory judgment under section 7428 and if the contributor (1) had

knowledge of the revocation of the ruling

or determination letter, (2) was aware that

such revocation was imminent, or (3) was

in part responsible for or was aware of the

activities or omissions of the organization

that brought about this revocation.

Effective Date of Revocation

01/01/2023

01/01/2022

12/31/2022

03/01/2023

1569

If on the other hand a suit for declaratory judgment has been timely filed,

contributions from individuals and organizations described in section 170(c)(2)

that are otherwise allowable will continue to be deductible. Protection under

section 7428(c) would begin on May 13,

2026, and would end on the date the court

first determines the organization is not

described in section 170(c)(2) as more

particularly set for in section 7428(c)(1).

For individual contributors, the maximum

deduction protected is $1,000, with a husband and wife treated as one contributor.

This benefit is not extended to any individual, in whole or in part, for the acts or

omissions of the organization that were

the basis for revocation.

Location

Pawtucket, RI

Kingston, PA

Rocklin, CA

Petoskey, MI

Mackinac Island, MI

Erie, PA

June 1, 2026

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2026–23

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

June 1, 2026

Numerical Finding List1

Bulletin 2026–23

Announcements:

2026-1, 2026-04 I.R.B. 402

2026-2, 2026-05 I.R.B. 447

2026-3, 2026-06 I.R.B. 518

2026-4, 2026-06 I.R.B. 533

2026-5, 2026-07 I.R.B. 540

2026-6, 2026-10 I.R.B. 634

2026-7, 2026-11 I.R.B. 697

2026-8, 2026-16 I.R.B. 813

2026-9, 2026-18 I.R.B. 881

2026-10, 2026-23 I.R.B. 1569

AOD:

2026-1, 2026-23 I.R.B. 1556

Notices:

2026-2, 2026-02 I.R.B. 304

2026-3, 2026-02 I.R.B. 307

2026-5, 2026-02 I.R.B. 309

2026-6, 2026-02 I.R.B. 313

2026-1, 2026-04 I.R.B. 365

2026-8, 2026-04 I.R.B. 368

2026-10, 2026-04 I.R.B. 378

2026-11, 2026-06 I.R.B. 491

2026-12, 2026-06 I.R.B. 496

2026-13, 2026-06 I.R.B. 499

2026-9, 2026-07 I.R.B. 534

2026-7, 2026-11 I.R.B. 637

2026-14, 2026-11 I.R.B. 654

2026-15, 2026-11 I.R.B. 658

2026-16, 2026-11 I.R.B. 685

2026-17, 2026-12 I.R.B. 698

2026-4, 2026-13 I.R.B. 726

2026-19, 2026-15 I.R.B. 797

2026-20, 2026-15 I.R.B. 800

2026-22, 2026-15 I.R.B. 802

2026-23, 2026-15 I.R.B. 804

2026-24, 2026-17 I.R.B. 835

2026-25, 2026-17 I.R.B. 836

2026-26, 2026-18 I.R.B. 878

2026-27, 2026-21 I.R.B. 1502

2026-29, 2026-22 I.R.B. 1537

2026-30, 2026-22 I.R.B. 1538

2026-31, 2026-23 I.R.B. 1562

2026-34, 2026-23 I.R.B. 1565

Proposed Regulations:

REG-101952-24, 2026-03 I.R.B. 345

REG-110519-25, 2026-03 I.R.B. 353

REG-132251-11; REG-134219-08,

2026-03 I.R.B. 358

REG-103430-24, 2026-05 I.R.B. 447

Proposed Regulations:—Continued

Treasury Decisions:—Continued

REG-112829-25, 2026-05 I.R.B. 452

REG-113515-25, 2026-05 I.R.B. 455

REG-121244-23, 2026-09 I.R.B. 579

REG-105064-25, 2026-13 I.R.B. 735

REG-108921-25, 2026-13 I.R.B. 756

REG-117002-25, 2026-13 I.R.B. 761

REG-117270-25, 2026-13 I.R.B. 772

REG-117298-21, 2026-14 I.R.B. 784

REG-114499-25, 2026-18 I.R.B. 883

REG-113229-25, 2026-19 I.R.B. 900

REG-108706-25, 2026-21 I.R.B. 1508

REG-119294-25, 2026-21 I.R.B. 1509

10045, 2026-21 I.R.B. 1491

10047, 2026-21 I.R.B. 1494

10046, 2026-22 I.R.B. 1512

10048, 2026-23 I.R.B. 1558

Revenue Procedures:

2026-1, 2026-01 I.R.B. 1

2026-2, 2026-01 I.R.B. 119

2026-3, 2026-01 I.R.B. 143

2026-4, 2026-01 I.R.B. 160

2026-5, 2026-01 I.R.B. 258

2026-6, 2026-02 I.R.B. 314

2026-7, 2026-02 I.R.B. 316

2026-8, 2026-04 I.R.B. 380

2026-9, 2026-04 I.R.B. 393

2026-10, 2026-04 I.R.B. 394

2026-12, 2026-07 I.R.B. 535

2026-13, 2026-09 I.R.B. 563

2026-11, 2026-12 I.R.B. 707

2026-15, 2026-13 I.R.B. 729

2026-16, 2026-13 I.R.B. 733

2026-17, 2026-15 I.R.B. 805

2026-19, 2026-19 I.R.B. 899

2026-14, 2026-20 I.R.B. 910

2026-21, 2026-22 I.R.B. 1538

2026-22, 2026-22 I.R.B. 1541

2026-23, 2026-22 I.R.B. 1542

Revenue Rulings:

2026-1, 2026-02 I.R.B. 299

2026-2, 2026-03 I.R.B. 342

2026-3, 2026-06 I.R.B. 485

2026-4, 2026-06 I.R.B. 487

2026-5, 2026-08 I.R.B. 542

2026-6, 2026-11 I.R.B. 635

2026-7, 2026-15 I.R.B. 791

2026-8, 2026-16 I.R.B. 812

2026-9, 2026-19 I.R.B. 897

2026-10, 2026-22 I.R.B. 1515

Treasury Decisions:

10042, 2026-03 I.R.B. 320

10041, 2026-04 I.R.B. 360

10039, 2026-05 I.R.B. 403

10040, 2026-05 I.R.B. 416

10043, 2026-15 I.R.B. 793

10044, 2026-18 I.R.B. 840

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2024–52, dated December 22, 2024.

June 1, 2026

Bulletin No. 2026–23

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–23

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2024–52, dated December 22, 2024.

Bulletin No. 2026–23

iii

June 1, 2026

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.