# Bulletin No. 2026–36

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A280201aa3f590648

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42

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
63
0.000863380
64
0.000877091
65
0.000890801
66
0.000904512
67
0.000918223
68
0.000931934
69
0.000945646
70
0.000959357
71
0.000973069
72
0.000986781
73
0.001000493
74
0.001014206
75
0.001027918
76
0.001041631
77
0.001055344
78
0.001069057
79
0.001082770
80
0.001096484
81
0.001110197
82
0.001123911
83
0.001137625
84
0.001151339
85
0.001165054
86
0.001178768
87
0.001192483
88
0.001206198
89
0.001219913
90
0.001233629
91
0.001247344
92
0.001261060
93
0.001274776
94
0.001288492
95
0.001302208
96
0.001315925
97
0.001329641
98
0.001343358
99
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

43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62

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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42

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
63
0.000861020
64
0.000874693
65
0.000888366
66
0.000902040
67
0.000915713
68
0.000929387
69
0.000943061
70
0.000956735
71
0.000970409
72
0.000984084
73
0.000997758
74
0.001011433
75
0.001025108
76
0.001038783
77
0.001052459
78
0.001066134
79
0.001079810
80
0.001093486
81
0.001107162
82
0.001120839
83
0.001134515
84
0.001148192
85
0.001161869
86
0.001175546
87
0.001189223
88
0.001202900
89
0.001216578
90
0.001230256
91
0.001243934
92
0.001257612
93
0.001271291
94
0.001284969
95
0.001298648
96
0.001312327
97
0.001326006
98
0.001339685
99
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

43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62

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

6%
9%
7%
6%
12%
20%
16%
11%
11%
11%
13%
11%
10%
9%

Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table

In 1995–1 C.B.
DAILY RATE TABLE
2,
pg.
4,
pg.
3,
pg.
2,
pg.
5,
pg.
6,
pg.
37,
pg.
27,
pg.
75,
pg.
75,
pg.
31,
pg.
27,
pg.
25,
pg.
23,
pg.

557
559
558
557
560
560
591
581
629
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
8%
8%
8%
9%
10%
9%
9%
10%
10%
11%
11%
10%
10%
10%
10%
10%
10%
9%
9%
9%
8%

OVERPAYMENTS
1995–1 C.B.
TABLE
PG
21
575
21
575
21
575
23
577
73
627
71
625
71
625
73
627
25
579
27
581
27
581
25
579
25
579
25
579
25
579
25
579
25
579
23
577
23
577
23
577
69
623

221

UNDERPAYMENTS
1995–1 C.B. RATE
RATE
TABLE
PG
9%
23
577
9%
23
577
9%
23
577
10%
25
579
11%
75
629
10%
73
627
10%
73
627
11%
75
629
11%
27
581
12%
29
583
12%
29
583
11%
27
581
11%
27
581
11%
27
581
11%
27
581
11%
27
581
11%
27
581
10%
25
579
10%
25
579
10%
25
579
9%
71
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

7%
7%
6%
6%
6%
6%
6%
6%
6%
7%
8%
8%
9%
8%
8%
8%
7%
8%
8%
8%
8%
8%
8%
8%
7%
7%
7%

67
67
65
17
17
17
17
17
17
19
21
21
23
21
21
69
67
69
69
21
21
21
21
21
19
19
19

222

621
621
619
571
571
571
571
571
571
573
575
575
577
575
575
623
621
623
623
575
575
575
575
575
573
573
573

8%
8%
7%
7%
7%
7%
7%
7%
7%
8%
9%
9%
10%
9%
9%
9%
8%
9%
9%
9%
9%
9%
9%
9%
8%
8%
8%

69
69
67
19
19
19
19
19
19
21
23
23
25
23
23
71
69
71
71
23
23
23
23
23
21
21
21

623
623
621
573
573
573
573
573
573
575
577
577
579
577
577
625
623
625
625
577
577
577
577
577
575
575
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
7%
8%
8%
8%
8%
9%
9%
9%
9%
8%
7%
7%
6%
6%
6%
6%
5%
5%
5%
4%
4%
5%
4%
5%
5%
6%
6%
7%
7%
7%
8%
8%
8%
8%
8%
8%
7%
6%
5%
6%
5%

223

TABLE
19
21
21
21
69
71
71
71
23
21
19
19
17
17
17
17
15
15
15
13
61
63
61
63
15
17
17
19
19
19
21
21
21
21
21
21
67
65
63
65
15

PAGE
573
575
575
575
623
625
625
625
577
575
573
573
571
571
571
571
569
569
569
567
615
617
615
617
569
571
571
573
573
573
575
575
575
575
575
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

4%
4%
4%
4%
4%
4%
4%
3%
4%
4%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
4%
4%
4%
4%
4%
4%
4%
4%
5%
5%
5%
6%
6%
5%
5%
5%
5%

August 31, 2026

224

13
13
13
13
13
13
13
11
13
13
11
59
59
59
59
11
11
11
11
11
11
11
11
11
11
11
11
59
61
61
61
13
13
13
13
13
15
15
15
17
17
15
15
63
63

567
567
567
567
567
567
567
565
567
567
565
613
613
613
613
565
565
565
565
565
565
565
565
565
565
565
565
613
615
615
615
567
567
567
567
567
569
569
569
571
571
569
569
617
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

3%
3%
3%
3%
3%
3%
3%
4%
5%
6%
7%
7%
7%
8%
8%
8%
8%
8%
7%
7%
7%
7%
7%
6%
7%
7%

Bulletin No. 2026–36

225

59
59
11
11
11
11
11
13
15
17
19
19
19
21
69
69
69
69
19
19
19
19
19
17
19
19

613
613
565
565
565
565
565
567
569
571
573
573
573
575
623
623
623
623
573
573
573
573
573
571
573
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
6%
17
7%
19
7%
19
7%
19
7%
67
8%
69
8%
69
8%
69
8%
21
7%
19
6%
17
6%
17
5%
15
5%
15
5%
15
5%
15
4%
13
4%
13
4%
13
3%
11
3%
59
4%
61
3%
59
4%
61
4%
13
5%
15
5%
15
6%
17
6%
17
6%
17
7%
19
7%
19
7%
19
7%
19
7%
19
7%
19
6%
65
5%
63
4%
61
5%
63

226

PG
571
573
573
573
621
623
623
623
575
573
571
571
569
569
569
569
567
567
567
565
613
615
613
615
567
569
569
571
571
571
573
573
573
573
573
573
619
617
615
617

UNDERPAYMENTS
1995–1 C.B.
RATE
TABLE
PG
7%
19
573
8%
21
575
8%
21
575
8%
21
575
8%
69
623
9%
71
625
9%
71
625
9%
71
625
9%
23
577
8%
21
575
7%
19
573
7%
19
573
6%
17
571
6%
17
571
6%
17
571
6%
17
571
5%
15
569
5%
15
569
5%
15
569
4%
13
567
4%
61
615
5%
63
617
4%
61
615
5%
63
617
5%
15
569
6%
17
571
6%
17
571
7%
19
573
7%
19
573
7%
19
573
8%
21
575
8%
21
575
8%
21
575
8%
21
575
8%
21
575
8%
21
575
7%
67
621
6%
65
619
5%
63
617
6%
65
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

4%
3%
3%
3%
3%
3%
3%
3%
2%
3%
3%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
2%
3%
3%
3%
3%
3%
3%
3%
3%
4%
4%
4%
5%
5%
4%
4%
4%

13
11
11
11
11
11
11
11
9
11
11
9
57
57
57
57
9
9
9
9
9
9
9
9
9
9
9
9
57
59
59
59
11
11
11
11
11
13
13
13
15
15
13
13
61

227

567
565
565
565
565
565
565
565
563
565
565
563
611
611
611
611
563
563
563
563
563
563
563
563
563
563
563
563
611
613
613
613
565
565
565
565
565
567
567
567
569
569
567
567
615

5%
4%
4%
4%
4%
4%
4%
4%
3%
4%
4%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
3%
4%
4%
4%
4%
4%
4%
4%
4%
5%
5%
5%
6%
6%
5%
5%
5%

15
13
13
13
13
13
13
13
11
13
13
11
59
59
59
59
11
11
11
11
11
11
11
11
11
11
11
11
59
61
61
61
13
13
13
13
13
15
15
15
17
17
15
15
63

569
567
567
567
567
567
567
567
565
567
567
565
613
613
613
613
565
565
565
565
565
565
565
565
565
565
565
565
613
615
615
615
567
567
567
567
567
569
569
569
571
571
569
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

4%
2%
2%
2%
2%
2%
2%
2%
3%
4%
5%
6%
6%
6%
7%
7%
7%
7%
7%
6%
6%
6%
6%
6%
5%
6%
6%

61
57
57
9
9
9
9
9
11
13
15
17
17
17
19
67
67
67
67
17
17
17
17
17
15
17
17

228

615
611
611
563
563
563
563
563
565
567
569
571
571
571
573
621
621
621
621
571
571
571
571
571
569
571
571

5%
3%
3%
3%
3%
3%
3%
3%
4%
5%
6%
7%
7%
7%
8%
8%
8%
8%
8%
7%
7%
7%
7%
7%
6%
7%
7%

63
59
59
11
11
11
11
11
13
15
17
19
19
19
21
69
69
69
69
19
19
19
19
19
17
19
19

617
613
613
565
565
565
565
565
567
569
571
573
573
573
575
623
623
623
623
573
573
573
573
573
571
573
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%
12%
12%
11%
10%
10%
9%
9%
9%
9%
9%
9%
9%
10%
11%
11%
12%
11%
11%
11%
10%
11%
11%
11%
11%
11%
11%
11%
10%
10%
10%
9%
10%
10%
10%
10%
11%
11%
11%
11%

229

1995–1 C.B.
TABLE
31
29
29
29
75
73
73
71
23
23
23
23
23
23
25
27
27
29
27
27
75
73
75
75
27
27
27
27
27
25
25
25
23
25
25
25
73
75
75
75
27

PG
585
583
583
583
629
627
627
625
577
577
577
577
577
577
579
581
581
583
581
581
629
627
629
629
581
581
581
581
581
579
579
579
577
579
579
579
627
629
629
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%
9%
9%
8%
8%
8%
8%
7%
7%
7%
6%
6%
7%
6%
7%
7%
8%
8%
9%
9%
9%
10%
10%
10%
10%
10%
10%
9%
8%
7%
8%
7%
6%
6%
6%
6%
6%
6%
6%
5%
6%
6%
5%
5%
5%

230

25
23
23
21
21
21
21
19
19
19
17
65
67
65
67
19
21
21
23
23
23
25
25
25
25
25
25
71
69
67
69
19
17
17
17
17
17
17
17
15
17
17
15
63
63

579
577
577
575
575
575
575
573
573
573
571
619
621
619
621
573
575
575
577
577
577
579
579
579
579
579
579
625
623
621
623
573
571
571
571
571
571
571
571
569
571
571
569
617
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

5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
5%
6%
6%
6%
6%
6%
6%
6%
6%
7%
7%
7%
8%
8%
7%
7%
7%
7%
5%
5%
5%
5%
5%
5%
5%
6%
7%
8%
9%
9%
9%

Bulletin No. 2026–36

231

63
63
15
15
15
15
15
15
15
15
15
15
15
15
63
65
65
65
17
17
17
17
17
19
19
19
21
21
19
19
67
67
63
63
15
15
15
15
15
17
19
21
23
23
23

617
617
569
569
569
569
569
569
569
569
569
569
569
569
617
619
619
619
571
571
571
571
571
573
573
573
575
575
573
573
621
621
617
617
569
569
569
569
569
571
573
575
577
577
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%
10%
10%
10%
10%
9%
9%
9%
9%
9%
8%
9%
9%

232

25
73
73
73
73
23
23
23
23
23
21
23
23

579
627
627
627
627
577
577
577
577
577
575
577
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

PG

Jan. 1, 1995–Mar. 31, 1995

6.5%

18

572

Apr. 1, 1995–Jun. 30, 1995

7.5%

20

574

Jul. 1, 1995–Sep. 30, 1995

6.5%

18

572

Oct. 1, 1995–Dec. 31, 1995

6.5%

18

572

Jan. 1, 1996–Mar. 31, 1996

6.5%

66

620

Apr. 1, 1996–Jun. 30, 1996

5.5%

64

618

Jul. 1, 1996–Sep. 30, 1996

6.5%

66

620

Oct. 1, 1996–Dec. 31, 1996

6.5%

66

620

Jan. 1, 1997–Mar. 31, 1997

6.5%

18

572

Apr. 1, 1997–Jun. 30, 1997

6.5%

18

572

Jul. 1, 1997–Sep. 30, 1997

6.5%

18

572

Oct. 1, 1997–Dec. 31, 1997

6.5%

18

572

Jan. 1, 1998–Mar. 31, 1998

6.5%

18

572

Apr. 1, 1998–Jun. 30, 1998

5.5%

16

570

Jul. 1, 1998–Sep. 30, 1998

5.5%

16

570

Oct. 1, 1998–Dec. 31, 1998

5.5%

16

570

Jan. 1, 1999–Mar. 31, 1999

4.5%

14

568

Apr. 1, 1999–Sep. 30, 1999

5.5%

16

570

Jul. 1, 1999–Sep. 30, 1999

5.5%

16

570

Oct. 1, 1999–Dec. 31, 1999

5.5%

16

570

Jan. 1, 2000–Mar. 31, 2000

5.5%

64

618

Apr. 1, 2000–Jun. 30, 2000

6.5%

66

620

Jul. 1, 2000–Sep. 30, 2000

6.5%

66

620

Oct. 1, 2000–Dec. 31, 2000

6.5%

66

620

Jan. 1, 2001–Mar. 31, 2001

6.5%

18

572

Apr. 1, 2001–Jun. 30, 2001

5.5%

16

570

Jul. 1, 2001–Sep. 30, 2001

4.5%

14

568

Oct. 1, 2001–Dec. 31, 2001

4.5%

14

568

Jan. 1, 2002–Mar. 31, 2002

3.5%

12

566

Apr. 1, 2002–Jun. 30, 2002

3.5%

12

566

Jul. 1, 2002–Sep. 30, 2002

3.5%

12

566

Oct. 1, 2002–Dec. 31, 2002

3.5%

12

566

Jan. 1, 2003–Mar. 31, 2003

2.5%

10

564

Apr. 1, 2003–Jun. 30, 2003

2.5%

10

564

Jul. 1, 2003–Sep. 30, 2003

2.5%

10

564

Oct. 1, 2003–Dec. 31, 2003

1.5%

8

562

Jan. 1, 2004–Mar. 31, 2004

1.5%

56

610

Apr. 1, 2004–Jun. 30, 2004

2.5%

58

612

Bulletin No. 2026–36

233

August 31, 2026

Jul. 1, 2004–Sep. 30, 2004

1.5%

56

610

Oct. 1, 2004–Dec. 31, 2004

2.5%

58

612

Jan. 1, 2005–Mar. 31, 2005

2.5%

10

564

Apr. 1, 2005–Jun. 30, 2005

3.5%

12

566

Jul. 1, 2005–Sep. 30, 2005

3.5%

12

566

Oct. 1, 2005–Dec. 31, 2005

4.5%

14

568

Jan. 1, 2006–Mar. 31, 2006

4.5%

14

568

Apr. 1, 2006–Jun. 30, 2006

4.5%

14

568

Jul. 1, 2006–Sep. 30, 2006

5.5%

16

570

Oct. 1, 2006–Dec. 31, 2006

5.5%

16

570

Jan. 1, 2007–Mar. 31, 2007

5.5%

16

570

Apr. 1, 2007–Jun. 30, 2007

5.5%

16

570

Jul. 1, 2007–Sep. 30, 2007

5.5%

16

570

Oct. 1, 2007–Dec. 31, 2007

5.5%

16

570

Jan. 1, 2008–Mar. 31, 2008

4.5%

62

616

Apr. 1, 2008–Jun. 30, 2008

3.5%

60

614

Jul. 1, 2008–Sep. 30, 2008

2.5%

58

612

Oct. 1, 2008–Dec. 31, 2008

3.5%

60

614

Jan. 1, 2009–Mar. 31, 2009

2.5%

10

564

Apr. 1, 2009–Jun. 30, 2009

1.5%

8

562

Jul. 1, 2009–Sep. 30, 2009

1.5%

8

562

Oct. 1, 2009–Dec. 31, 2009

1.5%

8

562

Jan. 1, 2010–Mar. 31, 2010

1.5%

8

562

Apr. 1, 2010–Jun. 30, 2010

1.5%

8

562

Jul. 1, 2010–Sep. 30, 2010

1.5%

8

562

Oct. 1, 2010–Dec. 31, 2010

1.5%

8

562

Jan. 1, 2011–Mar. 31, 2011

0.5%*

Apr. 1, 2011–Jun. 30, 2011

1.5%

8

562

Jul. 1, 2011–Sep. 30, 2011

1.5%

8

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%

56

610

Jul. 1, 2016–Sep. 30, 2016

1.5%

56

610

Oct. 1, 2016–Dec. 31, 2016

1.5%

56

610

Jan. 1, 2017–Mar. 31, 2017

1.5%

8

562

Apr. 1, 2017–Jun. 30, 2017

1.5%

8

562

Jul. 1, 2017–Sep. 30, 2017

1.5%

8

562

Oct. 1, 2017–Dec. 31, 2017

1.5%

8

562

Jan. 1, 2018–Mar. 31, 2018

1.5%

8

562

Apr. 1, 2018–Jun. 30, 2018

2.5%

10

564

Jul. 1, 2018–Sep. 30, 2018

2.5%

10

564

Oct. 1, 2018–Dec. 31, 2018

2.5%

10

564

Jan. 1, 2019–Mar. 31, 2019

3.5%

12

566

Apr. 1, 2019–Jun. 30, 2019

3.5%

12

566

Jul. 1, 2019–Sep. 30, 2019

2.5%

10

564

Oct. 1, 2019–Dec. 31, 2019

2.5%

10

564

Jan. 1, 2020–Mar. 31, 2020

2.5%

58

612

Apr. 1, 2020–Jun. 30, 2020

2.5%

58

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%

8

562

Jul. 1, 2022–Sep. 30, 2022

2.5%

10

564

Oct. 1, 2022–Dec. 31, 2022

3.5%

12

566

Jan. 1, 2023–Mar. 31, 2023

4.5%

14

568

Apr. 1, 2023–Jun. 30, 2023

4.5%

14

568

Jul. 1, 2023–Sep. 30, 2023

4.5%

14

568

Oct. 1, 2023–Dec. 31, 2023

5.5%

16

570

Jan. 1, 2024–Mar. 31, 2024

5.5%

64

618

Apr. 1, 2024–Jun. 30, 2024

5.5%

64

618

Jul. 1, 2024–Sep. 30, 2024

5.5%

64

618

Oct. 1, 2024–Dec. 31, 2024

5.5%

64

618

Jan. 1, 2025–Mar. 31, 2025

4.5%

14

568

Apr. 1, 2025–Jun. 30, 2025

4.5%

14

568

Bulletin No. 2026–36

235

August 31, 2026

Jul. 1, 2025–Sep. 30, 2025

4.5%

14

568

Oct. 1, 2025–Dec. 31, 2025

4.5%

14

568

Jan. 1, 2026–Mar. 31, 2026

4.5%

14

568

Apr. 1, 2026–Jun. 30, 2026

3.5%

12

566

Jul. 1, 2026–Sep. 30, 2026

4.5%

14

568

Oct. 1, 2026–Dec. 31, 2026

4.5%

14

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

1

(C) any other exchange, board of trade,
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.
*****
(c) Exceptions. The requirement
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.
1
2

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
Register. 90 F.R. at 44603.
(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.

i

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.
1

August 31, 2026

ii

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.
1

Bulletin No. 2026–36

iii

August 31, 2026

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A280201aa3f590648. Public record. Not legal advice.