Bulletin No. 2026–36

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2026–36

August 31, 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

Rev. Rul. 2026-15, page 216.

Notice 2026-50, page 242.

Interest rates: underpayments and overpayments. The rates for

interest determined under Section 6621 of the code for the calendar quarter beginning October 1, 2026, 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.

T.D. 10053, page 237.

These final regulations amend regulations under section 3406

to change the threshold for when certain third party settlement organizations (TPSOs) are required to perform backup

withholding. These final regulations clarify that in the case of

certain payments made through third parties, the amount subject to backup withholding under section 3406 is determined

by taking into account the exception for de minimis payments

by TPSOs in section 6050W(e). These final regulations also

clarify the amount subject to backup withholding and clarify

situations when the threshold does not apply. The final regulations reflect recent changes to the statutory law.

Finding Lists begin on page ii.

This notice provides interim guidance, pending the issuance

of regulations, relating to the credit for carbon oxide sequestration under section 45Q of the Internal Revenue Code to

reflect the Environmental Protection Agency’s proposed

regulations to amend the Greenhouse Gas Reporting Program to remove reporting obligations imposed under subpart RR of 40 CFR part 98. See 90 F.R. 44591 (Sept. 16,

2025). This notice modifies and amplifies Notice 2026-1 by

expanding the scope of the safe harbor provided in Notice

2026-1 to include qualified carbon oxide that is used as a

tertiary injectant in a qualified enhanced oil or natural gas

recovery project and the determination of the amount of

qualified carbon oxide subject to recapture. This notice also

extends the applicability date of the safe harbor provided in

Notice 2026-1.

Rev. Rul. 2026-16, page 237.

The revenue ruling holds that ICE Endex, a regulated exchange

of the Netherlands, is a “qualified board or exchange” within

the meaning of section 1256(g)(7)(C).

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.

August 31, 2026

Bulletin No. 2026–36

Part I

Section 6621.—

Determination of Rate of

Interest

26 CFR 301.6621-1: Interest rate.

Rev. Rul. 2026-15

Section 6621 of the Internal Revenue Code establishes the interest rates

on overpayments and underpayments of

tax. Under section 6621(a)(1), the overpayment rate is the sum of the federal

short-term rate plus 3 percentage points (2

percentage points in the case of a corporation), except the rate for the portion of

a corporate overpayment of tax exceeding

$10,000 for a taxable period is the sum

of the federal short-term rate plus 0.5 of

a percentage point. Under section 6621(a)

(2), the underpayment rate is the sum of

the federal short-term rate plus 3 percentage points.

Section 6621(c) provides that for purposes of interest payable under section

6601 on any large corporate underpayment, the underpayment rate under section

6621(a)(2) is determined by substituting

“5 percentage points” for “3 percentage

points.” See section 6621(c) and section

301.6621-3 of the Regulations on Procedure and Administration for the definition

of a large corporate underpayment and

for the rules for determining the applicable date. Section 6621(c) and section

301.6621-3 are generally effective for

periods after December 31, 1990.

Section 6621(b)(1) provides that the

Secretary will determine the federal short-

August 31, 2026

term rate for the first month in each calendar quarter. Section 6621(b)(2)(A)

provides that the federal short-term rate

determined under section 6621(b)(1) for

any month applies during the first calendar quarter beginning after that month.

Section 6621(b)(3) provides that the federal short-term rate for any month is the

federal short-term rate determined during

that month by the Secretary in accordance

with section 1274(d), rounded to the nearest full percent (or, if a multiple of 1/2 of

1 percent, the rate is increased to the next

highest full percent).

Notice 88-59, 1988-1 C.B. 546,

announced that in determining the quarterly interest rates to be used for overpayments and underpayments of tax under

section 6621, the Internal Revenue Service will use the federal short-term rate

based on daily compounding because that

rate is most consistent with section 6621

which, pursuant to section 6622, is subject

to daily compounding.

The federal short-term rate determined in accordance with section

1274(d) during July 2026 is the rate published in Revenue Ruling 2026-13, 202632 IRB 132, to take effect beginning

August 1, 2026. The federal short-term

rate, rounded to the nearest full percent,

based on daily compounding determined

during the month of July 2026 is 4 percent. Accordingly, an overpayment rate

of 7 percent (6 percent in the case of a

corporation) and an underpayment rate of

7 percent are established for the calendar

quarter beginning October 1, 2026. The

overpayment rate for the portion of a corporate overpayment exceeding $10,000

216

for the calendar quarter beginning October 1, 2026, is 4.5 percent. The underpayment rate for large corporate underpayments for the calendar quarter beginning

October 1, 2026, is 9 percent. These rates

apply to amounts bearing interest during

that calendar quarter.

Sections 6654(a)(1) and 6655(a)

(1) provide that the underpayment rate

established under section 6621 applies

in determining the addition to tax under

sections 6654 and 6655 for failure to pay

estimated tax for any taxable year. Thus,

the 7 percent rate also applies to estimated

tax underpayments for the fourth calendar quarter beginning October 1, 2026.

In addition, pursuant to section 6603(d)

(4), the rate of interest on section 6603

deposits is 4 percent for the fourth calendar quarter in 2026.

Interest factors for daily compound

interest for annual rates of 4.5 percent, 6

percent, 7 percent and 9 percent are published in Tables 14, 17, 19 and 23 of Rev.

Proc. 95-17, 1995-1 C.B. 566, 569, 571,

and 575.

Annual interest rates to be compounded

daily pursuant to section 6622 that apply

for prior periods are set forth in the tables

accompanying this revenue ruling.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Casey R. Conrad of the Office of

the Associate Chief Counsel (Procedure

and Administration). For further information regarding this revenue ruling, contact

Mr. Conrad at (202) 317-6844 (not a tollfree number).

Bulletin No. 2026–36

Days

Factor

0.000013699

0.000027397

0.000041096

0.000054796

0.000068495

0.000082195

0.000095894

0.000109594

0.000123294

0.000136995

0.000150695

0.000164396

0.000178097

0.000191798

0.000205499

0.000219201

0.000232902

0.000246604

0.000260306

0.000274008

0.000287711

0.000301413

0.000315116

0.000328819

0.000342522

0.000356225

0.000369929

0.000383633

0.000397336

0.000411041

0.000424745

0.000438449

0.000452154

0.000465859

0.000479564

0.000493269

0.000506974

0.000520680

0.000534386

0.000548092

0.000561798

0.000575504

Bulletin No. 2026–36

365 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000863380

0.000877091

0.000890801

0.000904512

0.000918223

0.000931934

0.000945646

0.000959357

0.000973069

0.000986781

0.001000493

0.001014206

0.001027918

0.001041631

0.001055344

0.001069057

0.001082770

0.001096484

0.001110197

0.001123911

0.001137625

0.001151339

0.001165054

0.001178768

0.001192483

0.001206198

0.001219913

0.001233629

0.001247344

0.001261060

0.001274776

0.001288492

0.001302208

0.001315925

0.001329641

0.001343358

0.001357075

100

0.001370792

101

0.001384510

102

0.001398227

103

0.001411945

104

0.001425663

217

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

Factor

0.001713784

0.001727506

0.001741228

0.001754951

0.001768673

0.001782396

0.001796119

0.001809843

0.001823566

0.001837290

0.001851013

0.001864737

0.001878462

0.001892186

0.001905910

0.001919635

0.001933360

0.001947085

0.001960811

0.001974536

0.001988262

0.002001988

0.002015714

0.002029440

0.002043166

0.002056893

0.002070620

0.002084347

0.002098074

0.002111801

0.002125529

0.002139257

0.002152985

0.002166713

0.002180441

0.002194169

0.002207898

0.002221627

0.002235356

0.002249085

0.002262815

0.002276544

August 31, 2026

0.000589211

0.000602917

0.000616624

0.000630331

0.000644039

0.000657746

0.000671454

0.000685161

0.000698869

0.000712578

0.000726286

0.000739995

0.000753703

0.000767412

0.000781121

0.000794831

0.000808540

0.000822250

0.000835960

0.000849670

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001439381

0.001453100

0.001466818

0.001480537

0.001494256

0.001507975

0.001521694

0.001535414

0.001549133

0.001562853

0.001576573

0.001590293

0.001604014

0.001617734

0.001631455

0.001645176

0.001658897

0.001672619

0.001686340

0.001700062

218

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002290274

0.002304004

0.002317734

0.002331465

0.002345195

0.002358926

0.002372657

0.002386388

0.002400120

0.002413851

0.002427583

0.002441315

0.002455047

0.002468779

0.002482511

0.002496244

0.002509977

0.002523710

Bulletin No. 2026–36

Days

Factor

0.000013661

0.000027323

0.000040984

0.000054646

0.000068308

0.000081970

0.000095632

0.000109295

0.000122958

0.000136620

0.000150283

0.000163947

0.000177610

0.000191274

0.000204938

0.000218602

0.000232266

0.000245930

0.000259595

0.000273260

0.000286924

0.000300590

0.000314255

0.000327920

0.000341586

0.000355252

0.000368918

0.000382584

0.000396251

0.000409917

0.000423584

0.000437251

0.000450918

0.000464586

0.000478253

0.000491921

0.000505589

0.000519257

0.000532925

0.000546594

0.000560262

0.000573931

Bulletin No. 2026–36

366 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000861020

0.000874693

0.000888366

0.000902040

0.000915713

0.000929387

0.000943061

0.000956735

0.000970409

0.000984084

0.000997758

0.001011433

0.001025108

0.001038783

0.001052459

0.001066134

0.001079810

0.001093486

0.001107162

0.001120839

0.001134515

0.001148192

0.001161869

0.001175546

0.001189223

0.001202900

0.001216578

0.001230256

0.001243934

0.001257612

0.001271291

0.001284969

0.001298648

0.001312327

0.001326006

0.001339685

0.001353365

100

0.001367044

101

0.001380724

102

0.001394404

103

0.001408085

104

0.001421765

219

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

Factor

0.001709097

0.001722782

0.001736467

0.001750152

0.001763837

0.001777522

0.001791208

0.001804893

0.001818579

0.001832265

0.001845951

0.001859638

0.001873324

0.001887011

0.001900698

0.001914385

0.001928073

0.001941760

0.001955448

0.001969136

0.001982824

0.001996512

0.002010201

0.002023889

0.002037578

0.002051267

0.002064957

0.002078646

0.002092336

0.002106025

0.002119715

0.002133405

0.002147096

0.002160786

0.002174477

0.002188168

0.002201859

0.002215550

0.002229242

0.002242933

0.002256625

0.002270317

August 31, 2026

0.000587600

0.000601269

0.000614939

0.000628608

0.000642278

0.000655948

0.000669618

0.000683289

0.000696959

0.000710630

0.000724301

0.000737972

0.000751643

0.000765315

0.000778986

0.000792658

0.000806330

0.000820003

0.000833675

0.000847348

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001435446

0.001449127

0.001462808

0.001476489

0.001490170

0.001503852

0.001517533

0.001531215

0.001544897

0.001558580

0.001572262

0.001585945

0.001599628

0.001613311

0.001626994

0.001640678

0.001654361

0.001668045

0.001681729

0.001695413

220

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002284010

0.002297702

0.002311395

0.002325087

0.002338780

0.002352473

0.002366167

0.002379860

0.002393554

0.002407248

0.002420942

0.002434636

0.002448331

0.002462025

0.002475720

0.002489415

0.002503110

0.002516806

Bulletin No. 2026–36

TABLE OF INTEREST RATES

PERIODS BEFORE JUL. 1, 1975 – PERIODS ENDING DEC. 31, 1986

OVERPAYMENTS AND UNDERPAYMENTS

PERIOD

RATE

Before Jul. 1, 1975

Jul. 1, 1975–Jan. 31, 1976

Feb. 1, 1976–Jan. 31, 1978

Feb. 1, 1978–Jan. 31, 1980

Feb. 1, 1980–Jan. 31, 1982

Feb. 1, 1982–Dec. 31, 1982

Jan. 1, 1983–Jun. 30, 1983

Jul. 1, 1983–Dec. 31, 1983

Jan. 1, 1984–Jun. 30, 1984

Jul. 1, 1984–Dec. 31, 1984

Jan. 1, 1985–Dec. 31, 1985

Jul. 1, 1985–Dec. 31, 1985

Jan. 1, 1986–Jun. 30, 1986

Jul. 1, 1986–Dec. 31, 1986

12%

20%

16%

11%

13%

11%

10%

Table

In 1995–1 C.B.

DAILY RATE TABLE

pg.

37,

pg.

27,

pg.

75,

pg.

75,

pg.

31,

pg.

27,

pg.

25,

pg.

23,

pg.

557

559

558

557

560

591

581

629

585

581

579

577

TABLE OF INTEREST RATES

FROM JAN. 1, 1987 – Dec. 31, 1998

Jan. 1, 1987–Mar. 31, 1987

Apr. 1, 1987–Jun. 30, 1987

Jul. 1, 1987–Sep. 30, 1987

Oct. 1, 1987–Dec. 31, 1987

Jan. 1, 1988–Mar. 31, 1988

Apr. 1, 1988–Jun. 30, 1988

Jul. 1, 1988–Sep. 30, 1988

Oct. 1, 1988–Dec. 31, 1988

Jan. 1, 1989–Mar. 31, 1989

Apr. 1, 1989–Jun. 30, 1989

Jul. 1, 1989–Sep. 30, 1989

Oct. 1, 1989–Dec. 31, 1989

Jan. 1, 1990–Mar. 31, 1990

Apr. 1, 1990–Jun. 30, 1990

Jul. 1, 1990–Sep. 30, 1990

Oct. 1, 1990–Dec. 31, 1990

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

Bulletin No. 2026–36

RATE

10%

11%

10%

OVERPAYMENTS

1995–1 C.B.

TABLE

575

577

627

625

627

579

581

579

577

623

221

UNDERPAYMENTS

1995–1 C.B. RATE

RATE

TABLE

577

10%

579

11%

629

10%

627

10%

627

11%

629

11%

581

12%

583

12%

583

11%

581

11%

581

11%

581

11%

581

11%

581

11%

581

10%

579

10%

579

10%

579

625

August 31, 2026

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Mar. 31, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

August 31, 2026

222

621

619

571

573

575

577

575

623

621

623

575

573

10%

623

621

573

575

577

579

577

625

623

625

577

575

Bulletin No. 2026–36

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 – PRESENT

NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS

1995–1 C.B.

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Jan. 1, 2009–Mar. 31, 2009

Bulletin No. 2026–36

RATE

223

TABLE

PAGE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

619

569

August 31, 2026

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

August 31, 2026

224

567

565

567

565

613

565

613

615

567

569

571

569

617

Bulletin No. 2026–36

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023–Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

Apr. 1, 2026–Jun. 30, 2026

Jul. 1, 2026–Sep. 30, 2026

Oct. 1, 2026–Dec. 31, 2026

Bulletin No. 2026–36

225

613

565

567

569

571

573

575

623

573

571

573

August 31, 2026

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 – PRESENT

CORPORATE OVERPAYMENTS AND UNDERPAYMENTS

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 30, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

August 31, 2026

OVERPAYMENTS

1995–1 C.B.

RATE

TABLE

226

571

573

621

623

575

573

571

569

567

565

613

615

613

615

567

569

571

573

619

617

615

617

UNDERPAYMENTS

1995–1 C.B.

RATE

TABLE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

619

Bulletin No. 2026–36

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Bulletin No. 2026–36

227

567

565

563

565

563

611

563

611

613

565

567

569

567

615

569

567

565

567

565

613

565

613

615

567

569

571

569

617

August 31, 2026

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023–Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

Apr. 1, 2026–Jun. 30, 2026

Jul. 1, 2026–Sep. 30, 2026

Oct. 1, 2026–Dec. 31, 2026

August 31, 2026

228

615

611

563

565

567

569

571

573

621

571

569

571

617

613

565

567

569

571

573

575

623

573

571

573

Bulletin No. 2026–36

TABLE OF INTEREST RATES FOR

LARGE CORPORATE UNDERPAYMENTS

FROM JANUARY 1, 1991 – PRESENT

PERIOD

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Jun. 30, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Bulletin No. 2026–36

RATE

13%

12%

11%

10%

11%

12%

11%

10%

11%

10%

11%

229

1995–1 C.B.

TABLE

585

583

629

627

625

577

579

581

583

581

629

627

629

581

579

577

579

627

629

581

August 31, 2026

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Sep. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Sep. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

August 31, 2026

10%

230

579

577

575

573

571

619

621

619

621

573

575

577

579

625

623

621

623

573

571

569

571

569

617

Bulletin No. 2026–36

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023–Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

Bulletin No. 2026–36

231

617

569

617

619

571

573

575

573

621

617

569

571

573

575

577

August 31, 2026

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

Apr. 1, 2026–Jun. 30, 2026

Jul. 1, 2026–Sep. 30, 2026

Oct. 1, 2026–Dec. 31, 2026

August 31, 2026

10%

232

579

627

577

575

577

Bulletin No. 2026–36

TABLE OF INTEREST RATES FOR CORPORATE

OVERPAYMENTS EXCEEDING $10,000

FROM JANUARY 1, 1995 – PRESENT

1995–1 C.B.

PERIOD

RATE

TABLE

Jan. 1, 1995–Mar. 31, 1995

6.5%

572

Apr. 1, 1995–Jun. 30, 1995

7.5%

574

Jul. 1, 1995–Sep. 30, 1995

6.5%

572

Oct. 1, 1995–Dec. 31, 1995

6.5%

572

Jan. 1, 1996–Mar. 31, 1996

6.5%

620

Apr. 1, 1996–Jun. 30, 1996

5.5%

618

Jul. 1, 1996–Sep. 30, 1996

6.5%

620

Oct. 1, 1996–Dec. 31, 1996

6.5%

620

Jan. 1, 1997–Mar. 31, 1997

6.5%

572

Apr. 1, 1997–Jun. 30, 1997

6.5%

572

Jul. 1, 1997–Sep. 30, 1997

6.5%

572

Oct. 1, 1997–Dec. 31, 1997

6.5%

572

Jan. 1, 1998–Mar. 31, 1998

6.5%

572

Apr. 1, 1998–Jun. 30, 1998

5.5%

570

Jul. 1, 1998–Sep. 30, 1998

5.5%

570

Oct. 1, 1998–Dec. 31, 1998

5.5%

570

Jan. 1, 1999–Mar. 31, 1999

4.5%

568

Apr. 1, 1999–Sep. 30, 1999

5.5%

570

Jul. 1, 1999–Sep. 30, 1999

5.5%

570

Oct. 1, 1999–Dec. 31, 1999

5.5%

570

Jan. 1, 2000–Mar. 31, 2000

5.5%

618

Apr. 1, 2000–Jun. 30, 2000

6.5%

620

Jul. 1, 2000–Sep. 30, 2000

6.5%

620

Oct. 1, 2000–Dec. 31, 2000

6.5%

620

Jan. 1, 2001–Mar. 31, 2001

6.5%

572

Apr. 1, 2001–Jun. 30, 2001

5.5%

570

Jul. 1, 2001–Sep. 30, 2001

4.5%

568

Oct. 1, 2001–Dec. 31, 2001

4.5%

568

Jan. 1, 2002–Mar. 31, 2002

3.5%

566

Apr. 1, 2002–Jun. 30, 2002

3.5%

566

Jul. 1, 2002–Sep. 30, 2002

3.5%

566

Oct. 1, 2002–Dec. 31, 2002

3.5%

566

Jan. 1, 2003–Mar. 31, 2003

2.5%

564

Apr. 1, 2003–Jun. 30, 2003

2.5%

564

Jul. 1, 2003–Sep. 30, 2003

2.5%

564

Oct. 1, 2003–Dec. 31, 2003

1.5%

562

Jan. 1, 2004–Mar. 31, 2004

1.5%

610

Apr. 1, 2004–Jun. 30, 2004

2.5%

612

Bulletin No. 2026–36

233

August 31, 2026

Jul. 1, 2004–Sep. 30, 2004

1.5%

610

Oct. 1, 2004–Dec. 31, 2004

2.5%

612

Jan. 1, 2005–Mar. 31, 2005

2.5%

564

Apr. 1, 2005–Jun. 30, 2005

3.5%

566

Jul. 1, 2005–Sep. 30, 2005

3.5%

566

Oct. 1, 2005–Dec. 31, 2005

4.5%

568

Jan. 1, 2006–Mar. 31, 2006

4.5%

568

Apr. 1, 2006–Jun. 30, 2006

4.5%

568

Jul. 1, 2006–Sep. 30, 2006

5.5%

570

Oct. 1, 2006–Dec. 31, 2006

5.5%

570

Jan. 1, 2007–Mar. 31, 2007

5.5%

570

Apr. 1, 2007–Jun. 30, 2007

5.5%

570

Jul. 1, 2007–Sep. 30, 2007

5.5%

570

Oct. 1, 2007–Dec. 31, 2007

5.5%

570

Jan. 1, 2008–Mar. 31, 2008

4.5%

616

Apr. 1, 2008–Jun. 30, 2008

3.5%

614

Jul. 1, 2008–Sep. 30, 2008

2.5%

612

Oct. 1, 2008–Dec. 31, 2008

3.5%

614

Jan. 1, 2009–Mar. 31, 2009

2.5%

564

Apr. 1, 2009–Jun. 30, 2009

1.5%

562

Jul. 1, 2009–Sep. 30, 2009

1.5%

562

Oct. 1, 2009–Dec. 31, 2009

1.5%

562

Jan. 1, 2010–Mar. 31, 2010

1.5%

562

Apr. 1, 2010–Jun. 30, 2010

1.5%

562

Jul. 1, 2010–Sep. 30, 2010

1.5%

562

Oct. 1, 2010–Dec. 31, 2010

1.5%

562

Jan. 1, 2011–Mar. 31, 2011

0.5%*

Apr. 1, 2011–Jun. 30, 2011

1.5%

562

Jul. 1, 2011–Sep. 30, 2011

1.5%

562

Oct. 1, 2011–Dec. 31, 2011

0.5%*

Jan. 1, 2012–Mar. 31, 2012

0.5%*

Apr. 1, 2012–Jun. 30, 2012

0.5%*

Jul. 1, 2012–Sep. 30, 2012

0.5%*

Oct. 1, 2012–Dec. 31, 2012

0.5%*

Jan. 1, 2013–Mar. 31, 2013

0.5%*

Apr. 1, 2013–Jun. 30, 2013

0.5%*

Jul. 1, 2013–Sep. 30, 2013

0.5%*

Oct. 1, 2013–Dec. 31, 2013

0.5%*

Jan. 1, 2014–Mar. 31, 2014

0.5%*

Apr. 1, 2014–Jun. 30, 2014

0.5%*

Jul. 1, 2014–Sep. 30, 2014

0.5%*

Oct. 1, 2014–Dec. 31, 2014

0.5%*

August 31, 2026

234

Bulletin No. 2026–36

Jan. 1, 2015–Mar. 31, 2015

0.5%*

Apr. 1, 2015–Jun. 30, 2015

0.5%*

Jul. 1, 2015–Sep. 30, 2015

0.5%*

Oct. 1, 2015–Dec. 31, 2015

0.5%*

Jan. 1, 2016–Mar. 31, 2016

0.5%*

Apr. 1, 2016–Jun. 30, 2016

1.5%

610

Jul. 1, 2016–Sep. 30, 2016

1.5%

610

Oct. 1, 2016–Dec. 31, 2016

1.5%

610

Jan. 1, 2017–Mar. 31, 2017

1.5%

562

Apr. 1, 2017–Jun. 30, 2017

1.5%

562

Jul. 1, 2017–Sep. 30, 2017

1.5%

562

Oct. 1, 2017–Dec. 31, 2017

1.5%

562

Jan. 1, 2018–Mar. 31, 2018

1.5%

562

Apr. 1, 2018–Jun. 30, 2018

2.5%

564

Jul. 1, 2018–Sep. 30, 2018

2.5%

564

Oct. 1, 2018–Dec. 31, 2018

2.5%

564

Jan. 1, 2019–Mar. 31, 2019

3.5%

566

Apr. 1, 2019–Jun. 30, 2019

3.5%

566

Jul. 1, 2019–Sep. 30, 2019

2.5%

564

Oct. 1, 2019–Dec. 31, 2019

2.5%

564

Jan. 1, 2020–Mar. 31, 2020

2.5%

612

Apr. 1, 2020–Jun. 30, 2020

2.5%

612

Jul. 1, 2020–Sep. 30, 2020

0.5%*

Oct. 1, 2020–Dec. 31, 2020

0.5%*

Jan. 1, 2021–Mar. 31, 2021

0.5%*

Apr. 1, 2021–Jun. 30, 2021

0.5%*

Jul. 1, 2021–Sep. 30, 2021

0.5%*

Oct. 1, 2021–Dec. 31, 2021

0.5%*

Jan. 1, 2022–Mar. 31, 2022

0.5%*

Apr. 1, 2022–Jun. 30, 2022

1.5%

562

Jul. 1, 2022–Sep. 30, 2022

2.5%

564

Oct. 1, 2022–Dec. 31, 2022

3.5%

566

Jan. 1, 2023–Mar. 31, 2023

4.5%

568

Apr. 1, 2023–Jun. 30, 2023

4.5%

568

Jul. 1, 2023–Sep. 30, 2023

4.5%

568

Oct. 1, 2023–Dec. 31, 2023

5.5%

570

Jan. 1, 2024–Mar. 31, 2024

5.5%

618

Apr. 1, 2024–Jun. 30, 2024

5.5%

618

Jul. 1, 2024–Sep. 30, 2024

5.5%

618

Oct. 1, 2024–Dec. 31, 2024

5.5%

618

Jan. 1, 2025–Mar. 31, 2025

4.5%

568

Apr. 1, 2025–Jun. 30, 2025

4.5%

568

Bulletin No. 2026–36

235

August 31, 2026

Jul. 1, 2025–Sep. 30, 2025

4.5%

568

Oct. 1, 2025–Dec. 31, 2025

4.5%

568

Jan. 1, 2026–Mar. 31, 2026

4.5%

568

Apr. 1, 2026–Jun. 30, 2026

3.5%

566

Jul. 1, 2026–Sep. 30, 2026

4.5%

568

Oct. 1, 2026–Dec. 31, 2026

4.5%

568

* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of this Revenue

Ruling.

August 31, 2026

236

Bulletin No. 2026–36

Section 1256.—Section

1256 Contracts Marked to

Market

(Also §§ 446, 481, 7805; 1.446-1, 301.7805-1).

Rev. Rul. 2026-16

ISSUE

Is ICE Endex, which is a regulated

exchange of the Netherlands, a qualified

board or exchange within the meaning of

§ 1256(g)(7)(C) of the Internal Revenue

Code (Code)1?

FACTS

ICE Endex is a regulated exchange of

the Netherlands.

On December 23, 2011, the Commodity Futures Trading Commission (CFTC)

published final rules regarding the registration with the CFTC of foreign boards

of trade (FBOT). See Registration of Foreign Boards of Trade, 76 FR 80674 (Dec.

23, 2011), codified at 17 CFR Part 48, and

as amended by 89 FR 66201 (Aug. 15,

2024). The effective date for the final rules

generally was February 21, 2012. Under

the CFTC FBOT registration system, the

CFTC may issue an Order of Registration

to an FBOT, allowing the FBOT to provide direct access to its electronic trading and order matching system from the

United States.

On January 10, 2017, the CFTC

granted an Order of Registration to ICE

Endex under the CFTC FBOT registration system. An FBOT’s status under the

CFTC FBOT registration system is posted

online by the CFTC.

LAW

Section 1256(g)(7) provides that the

term “qualified board or exchange” means:

(A) a national securities exchange

that is registered with the Securities and

Exchange Commission,

(B) a domestic board of trade designated

as a contract market by the CFTC, or

or other market that the Secretary of the

Treasury or the Secretary’s delegate determines has rules adequate to carry out the

purposes of § 1256.

HOLDING

The Internal Revenue Service determines that ICE Endex, which is a regulated exchange of the Netherlands, is a

qualified board or exchange within the

meaning of § 1256(g)(7)(C) as long as

ICE Endex holds a valid Order of Registration under the CFTC FBOT registration

system.

PROSPECTIVE APPLICATION

Under the authority of § 7805(b)(8), this

revenue ruling is effective for ICE Endex

Contracts entered into on or after September 1, 2026. For purposes of this revenue

ruling, the term “ICE Endex Contracts”

means futures contracts and futures contract options that are traded on or subject to

the rules of ICE Endex, that are described

in § 1256(g)(1)(A), and that are not covered by the exception in § 1256(b)(2).

CHANGE IN METHOD OF

ACCOUNTING

A change in the treatment of ICE Endex

Contracts to reflect the determination

made in this revenue ruling is a change

in method of accounting within the meaning of §§ 446 and 481 and the regulations

thereunder. The Commissioner of Internal

Revenue grants consent to a taxpayer to

change its method of accounting for ICE

Endex Contracts entered into on or after

September 1, 2026, to the § 1256 markto-market method for the first taxable

year during which the taxpayer holds

such contracts. The requirement to file

a Form 3115, Application for Change in

Accounting Method, in § 1.446-1(e)(3)(i)

is waived. The change is made on a

cut-off basis and is inapplicable to ICE

Endex Contracts that were entered into

before September 1, 2026. Because the

change is made on a “cut-off” basis, there

is no potential omission or duplication

of income or deductions, and an adjustment under § 481 is neither permitted nor

required.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Shawn Tetelman of the Office of

Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue ruling, contact

Shawn Tetelman at (202) 317-7053 (not a

toll-free number).

26 CFR 31.3406(a)-1; 26 CFR 31.3406(b)(3)-5

TD 10053

DEPARTMENT OF THE

TREASURY

Internal Revenue Service

26 CFR Part 31

Backup Withholding on

Third Party Network

Transactions

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains

final regulations governing backup withholding on reportable payments with

respect to third party network transactions. The final regulations reflect recent

changes to the statutory law that affect the

backup withholding requirements for third

party settlement organizations who make

payments in settlement of third party network transactions.

DATES: Effective date: These regulations

are effective on August 10, 2026.

Applicability dates: For dates of

applicability, see §§ 31.3406(a)-1(e) and

31.3406(b)(3)-5(e).

Unless otherwise specified, all “Section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR Part 1).

Bulletin No. 2026–36

237

August 31, 2026

FOR FURTHER INFORMATION

CONTACT: Casey Conrad, Office of

Associate Chief Counsel (Procedure and

Administration) at (202) 317-6844 (not a

toll-free number).

extent not inconsistent with the Summary

of Comments section of this preamble, the

Explanation of Provisions section of the

preamble to the proposed regulations is

incorporated in this document.

SUPPLEMENTARY INFORMATION:

Summary of Comments

Authority

One commenter suggested that the

changes to the final regulations take

place prospectively only. The final regulations do not adopt this comment. The

changes to section 3406 made by section

70432(b)(1) of the OBBBA apply to calendar years beginning after December

31, 2024. These final regulations remove

provisions from the existing regulations that conflict with section 3406, as

amended by the OBBBA, and implement

the changes to section 3406 made by the

OBBBA. Thus, to prevent taxpayer confusion that might arise from a conflict

between the statutory text of section 3406

and the text of the regulations, and to

adhere to the effective date prescribed in

the OBBBA by Congress for the changes

made to section 3406, the applicability

date for these final regulations mirrors

the effective date of section 70432(b)

(1) of the OBBBA (that is, the final regulations apply with respect to payments

made in calendar years beginning after

December 31, 2024), consistent with the

proposed regulations.

One commenter expressed general support for the proposed regulations but recommended that the Treasury Department

and the IRS include additional information

in the preamble to this Treasury decision.

The commenter recommended the Treasury Department and the IRS add a compliance-and-enforcement-implications

section to this preamble to reduce tax controversy disputes and clarify that: (1) the

taxability of income is not affected by the

absence of a Form 1099-K, Payment Card

and Third Party Network Transactions,

or the absence of backup withholding

on payments made in settlement of third

party network transactions; (2) the new de

minimis threshold for backup withholding

does not create a safe harbor for structuring, account-splitting, or other conduct

intended to avoid information reporting

or backup withholding; and (3) that the

IRS may use enforcement tools during an

examination to confirm the amount of a

This document contains amendments

to the Regulations on Employment

Taxes and Collection of Income Tax at

the Source (26 CFR part 31) under section 3406 of the Internal Revenue Code

(Code). The final regulations are issued

under the authority conferred by section

3406(i) of the Code, which provides the

Secretary of the Treasury or the Secretary’s delegate (Secretary) with authority

to “prescribe such regulations as may be

necessary or appropriate to carry out the

purposes of [section 3406].”

The final regulations are also issued

pursuant to section 7805(a) of the Code,

which 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

This document contains amendments

to regulations under 26 CFR part 31.

On January 9, 2026, the Department of

the Treasury (Treasury Department) and

the IRS published in the Federal Register (91 FR 934) a notice of proposed

rulemaking (REG-112829-25) proposing

amendments to the regulations governing backup withholding on third party

network transactions under section 3406

(proposed regulations) to reflect the statutory changes made to section 3406(b)

by section 70432 of Public Law 119-21,

139 Stat. 72 (July 4, 2025), commonly

known as the One, Big, Beautiful Bill

Act (OBBBA). No public hearing was

requested or held with respect to the proposed regulations.

The Treasury Department and the IRS

received eight comments in response to the

proposed regulations. After consideration

of these comments, the proposed regulations are adopted without change. To the

August 31, 2026

238

taxpayer’s income regardless of whether

a taxpayer exceeds the de minimis third

party settlement organization (TPSO)

reporting or backup withholding threshold.

Although these recommendations are

outside of the scope of these regulations,

the Treasury Department and the IRS

agree that it is important to emphasize

that the taxability of payments and the

reportability of income on an income tax

return are not determined by whether the

IRS or the taxpayer receives a Form 1099K, or by whether backup withholding is

required with respect to a third party network transaction.

This commenter also recommended

that the Treasury Department and the IRS

clarify that TPSOs are responsible for

internally aggregating multiple accounts

with identical identifying information

indicating common beneficial ownership

or the same taxpayer identification number. Although this comment is also outside

of the scope of these regulations, the Treasury Department and the IRS agree that

it is helpful to clarify that the de minimis

TPSO reporting and backup withholding thresholds referenced throughout this

Treasury decision apply with respect to

each participating payee, as defined by

section 6050W(d)(1).

Three commenters expressed concerns

that the proposed regulations were confusing or could be drafted more clearly, but

none suggested any alternative language

or clarifying edits. The final regulations

do not make any changes with respect to

these comments, as the final regulations

merely implement statutory changes in

response to changes made by section

70432(b)(1) of the OBBBA.

One commenter submitted three separate comments and attached documents.

In one comment, the commenter requested

that the IRS transmit the commenter’s

comment and all related materials to

the Office of Management and Budget

(OMB), the Office of Information and

Regulatory Affairs (OIRA), the Government Accountability Office (GAO), and

the Department of the Treasury Office of

Inspector General for independent review

under the Paperwork Reduction Act, the

Administrative Procedure Act, the Regulatory Flexibility Act, and various Executive Orders governing regulatory review,

Bulletin No. 2026–36

economic impact, and burden reduction.

The commenter suggested that the Treasury Department and the IRS failed to

comply with relevant administrative

requirements in promulgating the proposed regulations, or at the least understated the expected burden and economic

impact on taxpayers.

The Treasury Department and the IRS

complied with all relevant administrative

laws, including the Paperwork Reduction Act, the Administrative Procedure

Act, the Regulatory Flexibility Act, and

applicable Executive Orders in the promulgation of the proposed regulations and

these final regulations. The description of

the Treasury Department and the IRS’s

compliance with these administrative

requirements can be found in the Special

Analyses section of the proposed regulations and the Special Analyses section in

this Treasury decision.

The commenter also submitted thirty

attachments that consisted of requests and

demands, the substantial majority of which

were outside of the scope of the proposed

regulations. For example, the commenter

requested that the Treasury Department

and the IRS coordinate with the Commodity Futures Trading Commission

(CFTC) to issue joint guidance clarifying

that CFTC commodity classification governs the section 3406 backup withholding

treatment of digital commodity settlement

payments. The commenter also requested

that the Treasury Department and the IRS

exempt certain types of payments from

all backup withholding, including patent

royalty payments, dividend payments, and

payments for defense-related goods and

services to defense technology companies registered under International Traffic

in Arms Regulations (22 CFR parts 120

through 130). No changes were made

based on these comments because these

final regulations are limited to backup

withholding on third party network transactions, not any broader issues related to

backup withholding.

The remaining comments were tangentially related to the subject matter of the

proposed regulations on their face but are

nonetheless outside of the scope of these

regulations. For example, one commenter

requested that the Treasury Department

and the IRS analyze the impact of adopting different section 6050W de minimis

Bulletin No. 2026–36

TPSO reporting thresholds and adopt

the commenter’s desired threshold of

$200,000 in payments and 10,000 transactions. The Treasury Department and the

IRS lack the authority to change the statutorily prescribed amount of the de minimis TPSO reporting threshold in these

final regulations. Instead, the final regulations implement the statutory requirement

under section 3406, as amended by section 70432(b)(1) of the OBBBA, to align

the backup withholding threshold for third

party network transactions with the de

minimis TPSO reporting threshold under

section 6050W.

To the extent a comment, or portion

of a comment, was not discussed in this

preamble, the Treasury Department and

the IRS determined that the comment, or

portion of the comment, pertained to topics outside of the scope of these final regulations.

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 OMB regarding

review of tax regulations.

II. Regulatory Flexibility Act

Pursuant to the Regulatory Flexibility

Act (5 U.S.C. chapter 6), it is hereby certified that these final regulations will not

have a significant economic impact on a

substantial number of small entities. The

final regulations affect any entity required

to file information returns reporting payments of third party network transactions.

The final regulations could affect a substantial number of small entities; however,

the economic impact of the final regulations is not likely to be significant because

the final regulations do not impose any

new requirements on small entities.

Rather, the final regulations clarify the

threshold at which entities are required to

backup withhold for reportable payments

where certain conditions are met. Because

the threshold to backup withhold on

third party network transaction payments

increases under the final regulations, the

239

final regulations would reduce the frequency with which entities must backup

withhold. Thus, the economic impact of

these final regulations is not likely to be

significant.

III. Paperwork Reduction Act

The Paperwork Reduction Act of 1995

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

requires that a Federal agency obtain the

approval of the OMB before collecting

information from the public, whether that

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 it displays a valid control number

assigned by the OMB.

The collection of information in these

final regulations relates to recordkeeping

and information reporting with respect to

backup withholding in §31.3406(b)(3)-5.

The collected information will be used by

the payor to determine whether payments

to the payee exceed a threshold that would

require backup withholding and the issuance of an information return. The burden

for these requirements is included with

the Form and Instructions for Form 945,

Annual Return of Withheld Federal Income

Tax. The Form 945 and Instructions for

Form 945 are approved under OMB control number 1545-0029 and the associated

burden is included in the estimates shown

in the Instructions for Form 941. The Form

941 and its instructions were updated in

March 2026, and any decrease in burden

associated with the statutory changes to

section 3406 is reflected in those instructions because the burden estimates were

based on statutory requirements in effect

as of October 1, 2025, which includes the

amendments made by section 70432(b)(1)

of the OBBBA.

IV. Submission to Small Business

Administration

Pursuant to section 7805(f) of the

Code, the proposed regulations preceding

these final regulations were submitted to

the Chief Counsel for the Office of Advocacy of the Small Business Administration

for comment on its impact on small business. No comments were received.

August 31, 2026

V. Unfunded Mandates Reform Act

Drafting Information

Section 202 of the Unfunded Mandates

Reform Act of 1995 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 in 1995

dollars, 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.

The principal author of these final regulations is the Office of Associate Chief

Counsel (Procedure and Administration).

However, other personnel from the Treasury Department and the IRS participated

in their development.

VI. Executive Order 13132: Federalism

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, do not impose

substantial direct compliance costs on

State and local governments, and do not

preempt State law within the meaning of

the Executive Order.

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).

Statement of Availability of IRS

Documents

IRS Revenue Rulings, Revenue Procedures, Notices, and other guidance cited in

this document are published in the Internal Revenue Bulletin (or Cumulative Bulletin) and are available from the Superintendent of Documents, U.S. Government

Printing Office, Washington, DC 20402,

or by visiting the IRS website at https://

www.irs.gov.

August 31, 2026

Amendments to the Regulations

to reportable interest and dividend payments.

*****

to withhold does not apply to certain

de minimis payments as described in

§§31.3406(b)(3)-1(b)(3), 31.3406(b)(3)5(b)(2), and 31.3406(b)(4)-1 or to payments exempt from withholding under

§§31.3406(g)-1 through 31.3406(g)-3.

*****

(e) Applicability date. The provisions

of this section apply with respect to payments made in calendar years beginning

after December 31, 2024.

Par. 3. Section 31.3406(b)(3)-5 is

amended by revising paragraphs (b) and

(e) to read as follows:

Accordingly, the Treasury Department

and the IRS amend 26 CFR part 31 as follows:

§31.3406(b)(3)-5 Reportable payments

of payment card and third party

network transactions.

PART 31–EMPLOYMENT TAXES

AND COLLECTION OF INCOME

TAX AT SOURCE

*****

(b) Amount subject to backup withholding–(1) In general. The amount described

in paragraph (a) of this section that is subject to withholding under section 3406 is

the amount subject to reporting under section 6050W.

(2) Third party network transactions.

In the case of payments made in settlement of third party network transactions,

the amount subject to withholding under

section 3406 is determined with regard to

the exception for de minimis payments

by third party settlement organizations in

section 6050W(e). A payment is treated as

a reportable payment under paragraph (a)

of this section only if, during the calendar year, the aggregate number of transactions with respect to the participating

payee exceeds the number of transactions

specified in section 6050W(e)(2) and the

aggregate amount of all reportable payment transactions with respect to such

participating payee exceeds the dollar

amount specified in section 6050W(e)

(1). The amount subject to withholding is

the entire amount of the transaction that

causes either the total number of transactions to exceed the number of transactions specified in section 6050W(e)(2), or

the entire amount of the transaction that

causes the total amount paid to the participating payee to exceed the dollar amount

List of Subjects in 26 CFR Part 31

Employment taxes, Income taxes,

Penalties, Pensions, Railroad retirement,

Reporting and recordkeeping requirements, Social security, Unemployment

compensation.

Paragraph 1. The authority citation

for part 31 continues to read in part as follows:

Authority: 26 U.S.C. 7805.

*****

Par. 2. Section 31.3406(a)-1 is

amended by revising paragraphs (a) and

(c), and adding paragraph (e) to read as

follows:

§31.3406(a)-1 Backup withholding

requirement on reportable payments.

(a) Overview. Under section 3406 of

the Internal Revenue Code (Code), a payor

must deduct and withhold an amount

equal to the product of the fourth lowest

rate of tax applicable under section 1(c)

of the Code and a reportable payment if a

condition for withholding exists. Reportable payments mean interest and dividend

payments (as defined in section 3406(b)

(2)) and other reportable payments (as

defined in section 3406(b)(3)). The conditions described in paragraph (b)(1) of this

section apply to all reportable payments,

including reportable interest and dividend

payments. The conditions described in

paragraph (b)(2) of this section apply only

240

Bulletin No. 2026–36

specified in section 6050W(e)(1) at the

time of such payment, whichever occurs

later, and the amount of any subsequent

transactions made to the participating

payee during the calendar year.

(3) Exception. Paragraph (b)(2) of this

section does not apply with respect to payments to any participating payee during

any calendar year if one or more payments

in settlement of third party network transactions made by the payor to the participating payee during the preceding calendar year were reportable payments.

(4) Examples. The provisions of this

paragraph (b) are illustrated by the following examples:

(i) Example 1. Platform A is a third party settlement organization (as defined in §1.6050W-1(c)(2)

of this chapter) and Y is a participating payee (as

defined in §1.6050W-1(a)(5)(i)(B) of this chapter).

A complies with all the requirements to solicit a

taxpayer identification number (TIN) from Y, but Y

does not provide its TIN to A. During calendar year

2026, A makes 201 payments in settlement of third

party network transactions that total $20,000.01. A

must backup withhold under paragraph (b)(2) of this

section on the entire amount of the 201st transaction

Bulletin No. 2026–36

because that transaction caused Y to exceed the de

minimis reporting threshold for calendar year 2026

of 200 transactions and $20,000 in gross payments.

(ii) Example 2. The facts are the same as in paragraph (b)(4)(i) of this section (Example 1). During

calendar year 2027, A makes 199 payments in settlement of third party network transactions that total

$18,000.00. A must backup withhold on each payment made to Y in settlement of a third party network transaction during 2027 under paragraph (b)

(3) of this section because one or more payments in

settlement of third party network transactions made

by A to Y during the preceding calendar year (2026)

were reportable payments.

(iii) Example 3. The facts are the same as in paragraph (b)(4)(ii) of this section (Example 2). During

calendar year 2028, A makes four payments in settlement of third party network transactions that total

$2,000.00. A must backup withhold on each payment

made in settlement of a third party network transaction during 2028 under paragraph (b)(3) of this

section because one or more payments in settlement

of third party network transactions made by A to

Y during the preceding calendar year (2027) were

reportable payments.

(iv) Example 4. The facts are the same as in paragraph (b)(4)(iii) of this section (Example 3). During

calendar year 2029, A made no payments in settlement of third party network transactions, and during

calendar year 2030, A makes 199 payments in set-

241

tlement of third party network transactions that total

$18,000.00. A is not required to backup withhold on

any payment made in settlement of third party network transactions during calendar year 2030 because

A did not make any reportable payments to Y during

the preceding calendar year (2029), and A did not

make payments in settlement of third party network

transactions that exceed the de minimis reporting

threshold.

*****

(e) Applicability date. The provisions

of this section apply with respect to payments made in calendar years beginning

after December 31, 2024.

Frank J. Bisignano,

Chief Executive Officer.

Approved: July 23, 2026.

Kenneth J. Kies.

Assistant Secretary of the Treasury

(Tax Policy).

(Filed by the Office of the Federal Register August

7, 2026, 8:45 a.m., and published in the issue of the

Federal Register for August 10, 2026, 91 FR 51391)

August 31, 2026

Part III

Safe Harbor for the

Credit for Carbon Oxide

Sequestration under

Section 45Q for Qualified

Carbon Oxide Reported

under Subpart RR

Notice 2026-50

SECTION 1. PURPOSE

Notice 2026-1, 2026-4 I.R.B. 365,

provides interim guidance, pending the

issuance of forthcoming proposed regulations, relating to the credit for carbon

oxide sequestration under § 45Q (§ 45Q

credit) of the Internal Revenue Code

(Code)1 in light of the Environmental

Protection Agency’s (EPA) proposed regulations to remove reporting obligations

regarding the geological sequestration of

carbon dioxide imposed under subpart

RR of 40 CFR part 98 (subpart RR) of

the Greenhouse Gas Reporting Program

(GHGRP). See 90 F.R. 44591 (Sept. 16,

2025). This notice modifies and amplifies

Notice 2026-1 by expanding the scope of

the safe harbor provided in Notice 2026-1

to include qualified carbon oxide that is

used as a tertiary injectant in a qualified

enhanced oil or natural gas recovery project and the determination of the amount

of qualified carbon oxide subject to recapture. This notice also extends the applicability date of the safe harbor provided in

Notice 2026-1.

SECTION 2. BACKGROUND

Notice 2026-1 provided a safe harbor

for determining eligibility for the § 45Q

credit for qualified carbon oxide that is

captured and disposed of in secure geological storage and not used as a tertiary

injectant in a qualified enhanced oil or

natural gas recovery project, but did not

address eligibility for qualified carbon

oxide that is used as a tertiary injectant

in a qualified enhanced oil or natural gas

recovery project because there were other

available reporting standards that could be

used to claim the § 45Q credit for 2025.

Stakeholders have explained, however,

that taxpayers claiming the § 45Q credit

for a qualified enhanced oil or natural gas

recovery project are potentially unable to

transition from the subpart RR standard

to other available reporting standards in

time to claim the § 45Q credit for 2025,

or would incur significant costs, timeline

constraints, and compliance issues in

trying to do so. Other stakeholders have

explained that the limited applicability of

the safe harbor to the storage of qualified

carbon oxide that occurs in calendar year

2025 is creating uncertainty for projects

with long investment horizons. Finally,

the Department of the Treasury (Treasury)

and the Internal Revenue Service (IRS)

have received inquiries as to whether taxpayers claiming the § 45Q credit may rely

upon the safe harbor provided in Notice

2026-1 to determine the amount of qualified carbon oxide securely stored in geological storage and the amount of qualified

carbon oxide leaked into the atmosphere

for purposes of determining the amount of

qualified carbon oxide subject to recapture

under § 1.45Q-5(a) and (c).

In view of the unique circumstances

resulting from the proposed removal of

subpart RR of the GHGRP, and in consultation with the Administrator of the EPA,

the Secretary of Energy, and the Secretary

of the Interior, the Treasury Department

and the IRS are extending and expanding

the safe harbor provided in Notice 2026-1

in the manner specified in this notice.

SECTION 3. MODIFICATIONS TO

NOTICE 2026-1

.01 Modification of Section 2 of Notice

2026-1. This section 3.01 modifies and

amplifies section 2 of Notice 2026-1 by

revising section 2.01(8), adding new

section 2.01(11) and (12), revising section 2.02(1) and (2), adding new section

2.02(5), and making several nonsubstantive modifications in other sections. As

so modified and amplified, section 2 of

Notice 2026-1 now reads:

SECTION 2. BACKGROUND

.01 Section 45Q.

(1) Section 45Q was added to the Code

by § 115 of Division B of the Energy

Improvement and Extension Act of 2008,

Pub. L. 110-343, 122 Stat. 3765, 3829

(Oct. 3, 2008). Section 45Q was amended

a number of times thereafter, including

most recently by § 70522 of Public Law

119-21, 139 Stat. 72, 279 (July 4, 2025),

commonly known as the One, Big, Beautiful Bill Act (OBBBA).2

(2) Section 45Q(a)(1) allows a credit

of $20 per metric ton of qualified carbon

oxide (i) captured by the taxpayer using

carbon capture equipment which is originally placed in service at a qualified facility before February 9, 2018; (ii) disposed

of by the taxpayer in secure geological

storage; and (iii) neither used by the taxpayer as a tertiary injectant in a qualified

enhanced oil or natural gas recovery project nor utilized in a manner described in §

45Q(f)(5).

(3) Section 45Q(a)(2) allows a credit

of $10 per metric ton of qualified carbon

oxide (i) captured by the taxpayer using

carbon capture equipment which is originally placed in service at a qualified facility before February 9, 2018; and (ii) either

(A) used by the taxpayer as a tertiary

injectant in a qualified enhanced oil or natural gas recovery project and disposed of

by the taxpayer in secure geological storage; or (B) utilized by the taxpayer in a

manner described in § 45Q(f)(5).

(4) Section 45Q(a)(3) allows a credit

of the applicable dollar amount (as determined under § 45Q(b)(1)) per metric ton

of qualified carbon oxide captured by the

taxpayer using carbon capture equipment

Unless otherwise specified, all “section” or “§” references are to the Code or the Income Tax Regulations (26 CFR part 1).

Section 70522 of the OBBBA modified § 45Q to disallow the credit if the taxpayer is a specified foreign entity as defined in § 7701(a)(51)(B) of the Code or a foreign-influenced entity as

defined in § 7701(a)(51)(D), determined without regard to clause (i)(II) thereof, for taxable years beginning after July 4, 2025. Section 70522 of the OBBBA also modified § 45Q to establish

parity between the credit amount for the different uses and utilization of qualified carbon oxide and the credit amount for disposal in secure geological storage for facilities or equipment

placed in service after July 4, 2025.

August 31, 2026

242

Bulletin No. 2026–36

which is originally placed in service at a

qualified facility on or after February 9,

2018, during the 12-year period beginning

on the date the equipment was originally

placed in service, and (i) disposed of by

the taxpayer in secure geological storage, (ii) used by the taxpayer as a tertiary

injectant in a qualified enhanced oil or natural gas recovery project and disposed of

by the taxpayer in secure geological storage, or (iii) utilized by the taxpayer in a

manner described in § 45Q(f)(5).

(5) Section 45Q(f)(2) directs the Secretary of the Treasury or the Secretary’s

delegate (Secretary), in consultation with

the EPA, the Secretary of Energy, and the

Secretary of the Interior, to establish regulations for determining adequate security measures for the geological storage

of qualified carbon oxide under § 45Q(a)

such that the qualified carbon oxide does

not escape into the atmosphere. Section 45Q(f)(2) further provides that the

term “geological storage of qualified carbon oxide” includes storage at deep saline

formations, oil and gas reservoirs, and

unminable coal seams under such conditions as the Secretary may determine

under such regulations.

(6) On June 2, 2020, the Treasury

Department and the IRS published a notice

of proposed rulemaking (REG-11233919) in the Federal Register (85 F.R.

34050) under § 45Q. After consideration

of all comments received in response to

the proposed regulations, on January 15,

2021, the Treasury Department and the

IRS, in consultation with the EPA, Department of Energy, and the Department of the

Interior, published final regulations in the

Federal Register under § 45Q. See T.D.

9944; 86 F.R. 4728, as corrected in 86 F.R.

16530 (March 30, 2021).

(7) Section 1.45Q-3(a) provides that,

in general, to qualify for the § 45Q credit,

a taxpayer must either physically or contractually dispose of captured qualified

carbon oxide in secure geological storage

in the manner provided in § 1.45Q-3(b), or

utilize qualified carbon oxide in a manner

conforming with § 45Q(f)(5) and § 1.45Q4. Secure geological storage includes, but

is not limited to, storage at deep saline

formations, oil and gas reservoirs, and

unminable coal seams.

(8) Section 1.45Q-3(b) provides that

for purposes of the § 45Q credit, qualified

Bulletin No. 2026–36

carbon oxide is considered disposed of

by the taxpayer in secure geological storage such that the qualified carbon oxide

does not escape into the atmosphere if the

qualified carbon oxide is (1) injected into

a well that (i) complies with applicable

Underground Injection Control (UIC) or

other regulations, located onshore or offshore under submerged lands within the

territorial jurisdiction of States or federal

waters, and (ii) is not used as a tertiary

injectant in a qualified enhanced oil or

natural gas recovery project, in compliance with applicable requirements under

subpart RR ; or (2) injected into a well that

(i) complies with applicable UIC or other

regulations, is located onshore or offshore

under submerged lands within the territorial jurisdiction of States or Federal waters,

and (ii) is used as a tertiary injectant in

a qualified enhanced oil or natural gas

recovery project and stored in compliance with applicable requirements under

subpart RR, or the International Organization for Standardization (ISO) standards

endorsed by the American National Standards Institute (ANSI) under CSA/ANSI

ISO 27916:2019, Carbon dioxide capture,

transportation and geological storage—

Carbon dioxide storage using enhanced

oil recovery (CO2-EOR) (CSA/ANSI ISO

27916:2019). Collectively, the storage of

qualified carbon oxide at a project complying with the requirements of § 1.45Q3(b)(1) or (2) is hereinafter referred to in

this notice as “secure geological storage.”

(9) Section 1.45Q-2(h)(5) provides

that, in general, carbon oxide that is

injected into an oil reservoir that is not

a qualified enhanced oil recovery project

under § 43(c)(2) of the Code due to circumstances such as the first injection of a

tertiary injectant occurring before 1991, or

because a petroleum engineer’s certification was not timely filed, cannot be treated

as qualified carbon oxide, disposed of in

secure geological storage, or utilized in a

manner described in § 45Q(f)(5). Section

1.45Q-2(h)(5) does not apply to an oil reservoir if: (i) the reservoir has permanently

ceased oil production; (ii) the operator

has obtained a UIC Class VI permit; and

(iii) the operator complies with subpart

RR.

(10) Section 1.45Q-3(d) provides that

for a qualified enhanced oil or natural gas

recovery project in which the taxpayer

243

reported volumes of carbon oxide to the

EPA pursuant to subpart RR, the taxpayer

may self-certify the volume of qualified

carbon oxide claimed for purposes of §

45Q. For a qualified enhanced oil or natural gas recovery project in which the

taxpayer determined volumes pursuant to

CSA/ANSI ISO 27916:2019, a taxpayer

may prepare documentation as outlined

in CSA/ANSI ISO 27916:2019 internally,

but all such documentation must be provided to a qualified independent engineer

or geologist, who then must certify that

the documentation provided, including

the mass balance calculations as well as

information regarding monitoring and

containment assurance, is accurate and

complete. The qualified independent

engineer or geologist certifying a project

must be duly registered or certified in any

State. The certification must contain an

affidavit from the certifying engineer or

geologist stating that he or she is independent from the taxpayer (and if an election

under § 45Q(f)(3)(B) has been made, the

affidavit must state that he or she is independent from both the electing taxpayer

and the credit claimant). Certifications

must be made annually and under penalties of perjury. For any leaked amount

of qualified carbon oxide (as defined in §

1.45Q-5(c)) that is determined pursuant

to CSA/ANSI ISO 27916:2019, the certification must also include a statement

that the quantity was determined in accordance with sound engineering principles.

Taxpayers that capture and dispose of

qualified carbon oxide giving rise to the

§ 45Q credit must file Form 8933, Carbon

Oxide Sequestration Credit, with a timely

filed Federal income tax return or Form

1065, U.S. Return of Partnership Income,

including extensions or amendments to

Federal income tax returns, Forms 1065,

or on administrative adjustment requests

under § 6227 (AARs), as applicable.

(11) Section 1.45Q-5(a) provides that

a recapture event occurs when qualified

carbon oxide for which a § 45Q credit

has been previously claimed ceases to

be disposed of in secure geological storage or used as a tertiary injectant during

the recapture period. The amount of such

carbon oxide that is securely stored in the

current year is determined according to

the applicable requirements of subpart RR

or CSA/ANSI ISO 27916:2019.

August 31, 2026

(12) Section 1.45Q-5(c) provides that

the metric tons of qualified carbon oxide

that has leaked to the atmosphere must

be quantified pursuant to the requirements of subpart RR or CSA/ANSI ISO

27916:2019.

.02 EPA Regulations.

(1) Under the Safe Drinking Water

Act and regulations promulgated thereunder, injection of carbon dioxide into

any underground reservoir requires the

operator to comply with UIC program

regulations and to obtain the appropriate

UIC well permits. The UIC program is

designed to protect underground sources

of drinking water from underground

injection. Under 40 CFR 146.5 (Classification of injection wells), Class II may be

an appropriate UIC well permit for wells

that inject fluids (including carbon dioxide) brought to the surface in connection

with conventional oil or natural gas production and which may be commingled

with waste waters from gas plants that are

an integral part of production operations,

unless those waters are classified as a hazardous waste at the time of injection, and

for wells which inject fluids (including

carbon oxides) for enhanced recovery of

oil or natural gas. Class VI is an appropriate UIC well permit for wells that are not

experimental in nature and that are used

for geologic sequestration of carbon dioxide beneath the lowermost formation containing an underground source of drinking

water; for wells used for geologic sequestration of carbon dioxide that have been

granted a waiver of the injection depth

requirements pursuant to requirements at

40 CFR 146.95; or for wells used for geologic sequestration of carbon dioxide that

have received an expansion to the areal

extent of an existing Class II enhanced oil

recovery or enhanced gas recovery aquifer

exemption pursuant to 40 CFR §§ 146.4

and 144.7(d).

(2) Operators that inject carbon dioxide underground are also subject to the

EPA’s GHGRP requirements set forth

at 40 CFR Part 98. Under 40 CFR Part

98, facilities that inject carbon dioxide

underground for long-term containment

of carbon dioxide in subsurface geologic

formations are specifically subject to

subpart RR (Geologic Sequestration of

Carbon Dioxide source category). Facilities that are subject to subpart RR must

August 31, 2026

report basic information on carbon dioxide received for injection, develop and

implement an EPA-approved site-specific Monitoring, Reporting, and Verification Plan (MRV Plan), and report

the amount of carbon dioxide geologically sequestered using a mass balance

approach and annual monitoring activities. Facilities that are subject to subpart

RR include UIC Class VI wells and those

UIC Class II wells that have opted into

being subject to subpart RR by submitting a proposed MRV Plan to, and receiving approval from, the EPA. Such facilities are required to prepare and submit

reports on a calendar year basis (Annual

Reports).

(3) Annual Reports generally must

be submitted no later than March 31 of

each calendar year for greenhouse gas

emissions in the previous calendar year.

40 CFR § 98.3(b). Annual Reports are

required to be submitted electronically in

a format specified by the Administrator

of the EPA. 40 CFR § 98.5(a). The EPA

generally requires Annual Reports to be

submitted through the EPA’s electronic

reporting system, e-GGRT. Historically,

the EPA has launched the e-GGRT system

in mid-February for a given reporting year.

See EPA, Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2024 Data, 90 F.R. 13085,

13087 (March 20, 2025). Annual Reports

undergo verification by the EPA, and

non-confidential data from these reports

are published on the EPA’s website.

(4) On September 16, 2025, the EPA

issued proposed regulations, Reconsideration of the Greenhouse Gas Reporting

Program, 90 F.R. 44591, proposing to

amend the GHGRP to remove program

obligations for most source categories,

including the obligations in subpart RR,

for reporting years after 2024. The proposed regulations would also revise 40

CFR Part 98 subpart A to extend the Part

98 (including subpart RR) reporting deadline for reporting year 2025 from March

31, 2026, to June 10, 2026. The EPA has

proposed that the amendments, if finalized, would become effective within sixty

days of publication in the Federal Register. Because the proposed amendments

would remove the reporting obligations

under subpart RR following reporting

year 2024, reporters would cease submit-

244

ting Annual Reports within sixty days of

publication of the final rule in the Federal

(5) On February 27, 2026, the EPA

issued a final rule extending the deadline

for Annual Reports for reporting year

2025 to October 30, 2026. See Extending

the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025, 91

F.R. 9712.

.02 Modification of Section 3 of Notice

2026-1. This section 3.02 modifies and

amplifies section 3 of Notice 2026-1 by

revising sections 3.01 and 3.02(1), (2),

and (3), and adding new section 3.02(4).

These changes expand the applicability of the safe harbor provided in Notice

2026-1 to (1) qualified carbon oxide that

is stored (i) at a qualified enhanced oil

or natural gas recovery project for which

the taxpayer received an EPA-approved

MRV plan, and (ii) in compliance with the

applicable requirements of subpart RR as

in effect on December 31, 2025, and (2)

the determination of the amount of qualified carbon oxide securely stored, and the

amount of qualified carbon oxide that has

leaked into the atmosphere, for purposes

of satisfying the recapture requirements of

§ 1.45Q-5(a) and (c). As so modified and

amplified, section 3 of Notice 2026-1 now

reads as follows:

SECTION 3. SAFE HARBOR FOR

SECURE GEOLOGICAL STORAGE

OCCURRING ON OR AFTER

JANUARY 1, 2025

.01 In General. This section describes

a safe harbor (Safe Harbor) that taxpayers

may use for certain reporting years in which

secure geological storage occurs (relevant

reporting year) to satisfy the requirements

of § 1.45Q-3(b)(1)(ii), § 1.45Q-3(b)(2)

(ii), or § 1.45Q-2(h)(5)(iii), as applicable, § 1.45Q-3(d), and § 1.45Q-5(a) and

(c), in the event the EPA does not launch

the e-GGRT by March 31 of the calendar

year immediately following the relevant

reporting year (e-GGRT Unavailability).

The Safe Harbor does not apply in the

event the EPA launches the e-GGRT for

the relevant reporting year by March 31 of

the calendar year immediately following

the relevant reporting year.

.02 Safe Harbor for Secure Geological

Storage.

Bulletin No. 2026–36

(1) In General. Taxpayers following

the guidance set forth in section 3.02(2),

(3), and (4) of this notice will be considered to have satisfied: (i) the requirements

in § 1.45Q-3(b)(1)(ii), § 1.45Q-3(b)(2)

(ii), or § 1.45Q-2(h)(5)(iii), as applicable,

related to subpart RR (§ 45Q Subpart RR

Requirements); (ii) the requirements of §

1.45Q-3(d) (Certification Requirements);

and (iii) the requirements of § 1.45Q-5(a)

and (c) related to determining the amount

of qualified carbon oxide securely stored

and the quantity of qualified carbon oxide

leaked to the atmosphere (Recapture

Requirements).

(2) Compliance with § 45Q Subpart

RR Requirements. In the case of e-GGRT

Unavailability for a relevant reporting

year, the taxpayer performing secure geological storage in such reporting year will

be considered to have satisfied the § 45Q

Subpart RR Requirements for such reporting year if: (i) such storage complies with

the applicable requirements of subpart RR

as in effect on December 31, 2025; (ii)

the taxpayer received an EPA-approved

MRV plan for such project and the MRV

plan is applicable to the dates of such storage; and (iii) instead of submitting the

Annual Report for the relevant reporting

year with respect to such storage through

the e-GGRT pursuant to 40 CFR §§ 98.3

and 98.5, the taxpayer prepares and submits the Annual Report to an independent

engineer or geologist, who certifies the

Annual Report, in the manner specified in

section 3.02(3)(A) and (B) of this notice.

The Annual Report must contain all of the

information and documentation, including mass balance accounting calculations

and monitoring and containment assurance, that would have been required under

subpart RR as in effect on December 31,

2025.

(3) Compliance with Certification

Requirements. In the event of e-GGRT

Unavailability for a relevant reporting

year, the taxpayer performing secure geological storage will be considered to have

satisfied the Certification Requirements if

the taxpayer satisfies the requirements of

section 3.02(3)(A) and (B) of this notice

with respect to such storage.

(A) The taxpayer must submit the

Annual Report for the relevant reporting

year to a qualified independent engineer

or geologist. The qualified independent

Bulletin No. 2026–36

engineer or geologist certifying the information must be duly registered or certified

in any State.

(B) The qualified independent engineer

or geologist must certify that (i) the capture and disposal described in § 1.45Q3(b)(1), § 1.45Q-3(b)(2), or § 1.45Q-2(h)

(5), as applicable, is in compliance with

subpart RR as in effect on December 31,

2025, and (ii) the information and documentation contained in the Annual Report

for the relevant reporting year is accurate

and complete based upon the requirements under subpart RR as in effect on

December 31, 2025. The certification

must contain an affidavit from the certifying engineer or geologist stating that he or

she is independent from the taxpayer (and

if an election under § 45Q(f)(3)(B) has

been made, the affidavit must state that he

or she is independent from both the electing taxpayer and the credit claimant). The

certification must be made under penalties

of perjury.

(4) Compliance with Recapture

Requirements. In the event of e-GGRT

Unavailability for a relevant reporting

year, a taxpayer will be considered to have

satisfied the Recapture Requirements with

respect to any secure geological storage

subject to the Recapture Requirements if

the Annual Report for reporting year 2025

or later, certified in the manner specified

in section 3.02(3) of this notice, includes

the following determinations pursuant to

the applicable requirements of subpart RR

as in effect on December 31, 2025: (i) the

quantity of qualified carbon oxide that is

securely stored for the calendar year; and

(ii) the quantity, if any, in metric tons of

qualified carbon oxide that has leaked into

the atmosphere in such reporting year.

.03 Timely reporting. Taxpayers that

capture and dispose of qualified carbon

oxide giving rise to the § 45Q credit must

file a Form 8933 with a timely filed Federal income tax return or Form 1065,

including extensions, or amendments to

Federal income tax returns, Forms 1065,

or on AARs, as applicable. To rely upon

the Safe Harbor, a taxpayer must complete

all documentation and obtain the certification described in section 3.02(2) and (3) of

this notice by the time it (or, if an election

under § 45Q(f)(3)(B) has been made, any

credit claimant) timely files its relevant

tax return, as described in the preceding

245

sentence. Taxpayers should retain the documentation and certification described

in section 3.02(2) and (3) of this notice

in their books and records pursuant to §

6001. See also T.D. 9944; 86 F.R 4728,

4758-59.

.03 Modification of Section 5 of Notice

2026-1. This section 3.03 modifies and

amplifies section 5 of Notice 2026-1 by

extending the applicability of the Safe

Harbor to secure geological storage occurring on or after January 1, 2025, and on or

before December 31 of the calendar year

in which the Treasury Department and

the IRS publish further interim guidance

in the Internal Revenue Bulletin or forthcoming proposed regulations in the Federal Register addressing compliance with

measurement, reporting, and verification

requirements under § 45Q for secure geological storage. As so modified and amplified, section 5 of Notice 2026-1 now reads

as follows:

SECTION 5. APPLICABILITY DATE

This notice applies to secure geological storage occurring on or after January

1, 2025, and on or before December 31 of

the calendar year in which the Treasury

Department and the IRS publish further

interim guidance in the Internal Revenue

Bulletin or forthcoming proposed regulations in the Federal Register addressing compliance with requirements under

§ 45Q for secure geological storage. Taxpayers claiming the § 45Q credit for secure

geological storage occurring on or after

January 1, 2025, and on or before December 31 of the calendar year in which the

Treasury Department and the IRS publish

such guidance or forthcoming proposed

regulations may rely upon this notice to

satisfy the requirements of § 1.45Q-3(b)

(1)(ii), 1.45Q-3(b)(2)(ii), or 1.45Q-2(h)

(5)(iii), as applicable, § 1.45Q-3(d), and

§1.45Q-5(a) and (c).

SECTION 4. REQUEST FOR

COMMENTS

.01 Request for Comments.

The Treasury Department and the IRS,

in consultation with the Administrator of

the EPA, the Secretary of Energy, and the

Secretary of the Interior, request comments

on the appropriate standard to be used in

August 31, 2026

place of subpart RR to demonstrate compliance with § 45Q for secure geological

storage. In particular, the Treasury Department and the IRS request comments on

whether the International Organization for

Standardization’s standard 27914:2026—

Carbon dioxide capture, transportation and

storage—Geological storage (Ed. 2, 2026),

which was published in March 2026, could

be used as an alternative, including the

verification methods set forth therein. In

addition, the Treasury Department and the

IRS request comments on whether there

are other processes or methodologies that

could serve as suitable alternatives to subpart RR in the event the EPA finalizes its

regulations as proposed.

.02 Deadline for Submission.

Written comments should be submitted

by October 30, 2026. However, consideration will be given to any written com-

August 31, 2026

ments submitted after October 30, 2026, if

such consideration will not delay the issuance of future published guidance.

.03 Form and Manner.

The subject line for the comments

should include a reference to Notice 202650. All stakeholders are strongly encouraged to submit comments electronically.

Comments may be submitted in one of

two ways:

(1) Electronically via the Federal

eRulemaking Portal at https://www.regulations.gov (type IRS-2026-0728 in the

search field on the https://www.regulations.gov homepage to find this notice and

submit comments).

(2) By mail to: Internal Revenue Service, CC:PA:01:PR (Notice 2026-50),

Room 5503, P.O. Box 7604, Ben Franklin

Station, Washington, DC 20044.

.04 Publication of Comments.

246

The Treasury Department and the IRS

will publish for public availability any

comment submitted electronically or on

paper to the IRS’s public docket on https://

www.regulations.gov.

SECTION 5. EFFECT ON OTHER

DOCUMENTS

This notice modifies and amplifies

Notice 2026-1.

SECTION 6. DRAFTING

INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

(Energy, Credits, and Excise Tax). For

further information regarding this notice

contact (202) 317-6853 (not a toll-free

number).

Bulletin No. 2026–36

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. 2026–36

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.

August 31, 2026

Numerical Finding List1

Bulletin 2026–36

Announcements:

2026-11, 2026-29 I.R.B. 49

2026-12, 2026-29 I.R.B. 50

2026-13, 2026-32 I.R.B. 173

2026-14, 2026-34 I.R.B. 180

2026-15, 2026-35 I.R.B. 214

Notices:

2026-39, 2026-27 I.R.B. 1

2026-38, 2026-28 I.R.B. 30

2026-40, 2026-28 I.R.B. 33

2026-41, 2026-29 I.R.B. 39

2026-42, 2026-29 I.R.B. 41

2026-43, 2026-29 I.R.B. 42

2026-21, 2026-30 I.R.B. 51

2026-44, 2026-32 I.R.B. 143

2026-28, 2026-34 I.R.B. 177

2026-46, 2026-35 I.R.B. 182

2026-48, 2026-35 I.R.B. 185

2026-49, 2026-35 I.R.B. 198

2026-50, 2026-36 I.R.B. 242

Revenue Procedures:

2026-25, 2026-29 I.R.B. 45

2026-18, 2026-30 I.R.B. 53

2026-26, 2026-31 I.R.B. 131

2026-32, 2026-32 I.R.B. 146

2026-28, 2026-33 I.R.B. 175

2026-30, 2026-35 I.R.B. 212

Revenue Rulings:

2026-12, 2026-28 I.R.B. 27

2026-13, 2026-32 I.R.B. 132

2026-14, 2026-35 I.R.B. 181

2026-15, 2026-36 I.R.B. 216

2026-16, 2026-36 I.R.B. 237

Treasury Decisions:

10051, 2026-31 I.R.B. 118

10052, 2026-31 I.R.B. 121

10050, 2026-32 I.R.B. 134

10053, 2026-36 I.R.B. 237

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin

2025–52, dated December 21, 2025.

August 31, 2026

Bulletin No. 2026–36

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–36

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin

2025–52, dated December 21, 2025.

Bulletin No. 2026–36

iii

August 31, 2026

Internal Revenue Service

Washington, DC 20224

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