Bulletin No. 2026–26

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2026–26

June 22, 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.

ESTATE TAX

REG-103193-26, page 1593.

These proposed regulations would amend the current regulations to increase the amount of the user fee for authorized

persons who wish to request the issuance of IRS Letter 627,

also referred to as an estate tax closing letter. Pursuant to

the guidelines in OMB Circular A-25, the IRS has calculated

its cost of providing the estate tax closing letter to be $76.

EXCISE TAX, EXEMPT

ORGANIZATIONS

Notice 2026-36, page 1587.

This notice announces intent to issue proposed regulations

under section 4960 pertaining to the tax on excess tax-exempt organization executive compensation. It is anticipated

that the proposed regulations will address the expanded definition of covered employee made to section 4960 by the

Finding Lists begin on page ii.

OBBBA. This notice also provides transition relief for applicable tax-exempt organizations (ATEOs) and their related organizations, allowing for certain exceptions to the definition of

covered employee provided in the section 4960 regulations

to continue to apply until further guidance is issued. This

notice also solicits public comments.

INCOME TAX

Notice 2026-37, page 1589.

This notice publishes the inflation adjustment factor and

reference price for calendar year 2026 for the renewable

electricity production credit under section 45 of the Internal

Revenue Code. The 2026 inflation adjustment factor and

reference price are used in determining the availability of

the credit and apply to calendar year 2026 sales of kilowatt hours of electricity produced in the United States or

a possession thereof from qualified energy resources. This

notice also provides the credit amounts for calendar year

2026 under section 45.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

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

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

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

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

modify, or amend any of those previously published in the

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

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

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

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

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

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

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

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

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

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

Secretary (Enforcement).

Part IV.—Items of General Interest.

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

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

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

June 22, 2026 

Bulletin No. 2026–26

Part III

Notice of Intent to Issue

Regulations Under

Section 4960

Notice 2026-36

SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service

(IRS) intend to issue proposed regulations under section 4960 of the Internal

Revenue Code (Code)1 pertaining to the

tax on excess tax-exempt organization

executive compensation. It is anticipated

that the proposed regulations will address

the effective date of the amendment to

the definition of covered employee made

by section 70416 of Public Law 119-21,

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

known as the One, Big, Beautiful Bill

Act (OBBBA) and will also propose

exceptions to the definition of covered

employee that are similar to the limited

hours and nonexempt funds exceptions in

the existing section 4960 regulations. This

notice also solicits public comments on

the matters addressed in this notice.

SECTION 2. BACKGROUND

.01 Overview of section 4960. Section

4960 generally imposes an excise tax on

any applicable tax-exempt organization

(ATEO) or related person or governmental

entity that pays a covered employee remuneration in excess of $1 million in a taxable year or an excess parachute payment.

.02 Pre-OBBBA definition of covered

employee. As originally enacted in 2017

under Section 13602 of the Tax Cuts

and Jobs Act, Pub. L. No. 115-97, 131

Stat. 2054, 2157 (Dec. 22, 2017), section 4960(c)(2) of the Code defined a covered employee as any employee (including any former employee) of an ATEO if

the employee (1) is one of the five high-

1

est-compensated employees of the ATEO

for the taxable year, or (2) was a covered

employee of the ATEO (or any predecessor) for any preceding taxable year beginning after December 31, 2016. On January 19, 2021, the Treasury Department

and IRS published final regulations under

section 4960 in the Federal Register (T.D.

9938, 86 FR 6196) (section 4960 regulations).

.03 Exceptions to five highest-compensated employees under the section

4960 regulations. Section 53.4960-1(d)

(2) defines the term “five highest-compensated employees” of an ATEO. Section 53.4960-1(d)(2)(ii), (iii), and (iv) provide “limited hours,” “nonexempt funds,”

and “limited services” exceptions to this

definition, respectively. Under the section

4960 regulations, an individual meeting

any of these exceptions is disregarded for

purposes of determining an ATEO’s five

highest-compensated employees for a taxable year. An individual who was a covered employee of an ATEO (not qualifying

for an exception to being one of the five

highest-compensated employees) for any

taxable year beginning after December 31,

2016, remains a covered employee for all

future years because covered employee

status is permanent.

.04 Reason for the exceptions in the

section 4960 regulations. The limited

hours exception and nonexempt funds

exception were adopted in response to

commenters requesting exceptions for situations in which employees of non-ATEO

related organizations perform limited or

temporary services for the related ATEO

(in particular, while receiving no compensation from the ATEO). The limited services exception was adopted to prevent

an employee to whom the ATEO paid

minimal remuneration from displacing

an employee who would otherwise have

been one of the five highest-compensated

employees (and thus a covered employee)

of the ATEO.

.05 OBBBA changes to the definition

of covered employee. Section 70416 of

the OBBBA revised the definition of

“covered employee.” For taxable years

beginning after December 31, 2025, the

term “covered employee” means any

employee of an ATEO (or any predecessor of an ATEO) and any former employee

of an ATEO (or its predecessor) who was

such an employee during any taxable

year beginning after December 31, 2016.

Thus, after the OBBBA, the definition of

covered employee in section 4960 is no

longer limited to an ATEO’s five highest-compensated employees, and the section 4960 regulations’ exceptions to the

“five highest-compensated employees” of

an ATEO no longer apply by their terms.

SECTION 3. APPLICABILITY OF

POST-OBBBA DEFINITION OF

COVERED EMPLOYEE

Section 70416(b) of the OBBBA provides that the amendment to the definition of covered employee applies to

taxable years beginning after December

31, 2025. The Treasury Department and

the IRS interpret this effective-date provision to broaden the definition of covered employee only for taxable years of

an ATEO beginning after December 31,

2025, and to retain the prior definition of

covered employee for taxable years beginning on or before December 31, 2025,

including for purposes of determining for

a taxable year beginning after December

31, 2025, whether a former employee

was a covered employee in a taxable

year beginning on or before December

31, 2025. Accordingly, the definition of

covered employee under section 4960(c)

(2), as amended by the OBBBA, includes

only—

• Any individual who was an employee

of an ATEO in any taxable year beginning after December 31, 2016, and on

or before December 31, 2025, if the

individual was a covered employee

for the taxable year under prior law,

and

• Any individual who is an employee of

an ATEO in any taxable year beginning after December 31, 2025 (subject

Unless otherwise provided, all “section” references are to sections of the Code or the Regulations on Foundation and Similar Excise Taxes (26 CFR Part 53).

Bulletin No. 2026–26

1587

June 22, 2026

to any exceptions provided in future

guidance, such as those described in

section 4.01 of this notice).

SECTION 4. FORTHCOMING

PROPOSED REGULATIONS

.01 Intent to issue regulations. The

Treasury Department and the IRS intend

to issue proposed regulations (forthcoming proposed regulations) revising the

section 4960 regulations by removing references to an ATEO’s five highest-compensated employees and making conforming

changes. It is anticipated that the forthcoming proposed regulations would provide the interpretation of the post-OBBBA

definition of covered employee described

in section 3 of this notice. It is also anticipated that the proposed regulations would

provide covered employee exceptions

for limited hours and nonexempt funds

similar to those in section 53.4960-1(d)

(2)(ii) and (iii), but would not provide a

limited services exception to the amended

definition of covered employee because

the concern that motivated that exception—displacement of an employee who

would otherwise have been one of the

five highest-compensated employees of

the ATEO—is no longer relevant. The

forthcoming proposed regulations may

also address other issues, such as issues

reserved in the existing section 4960 regulations.

.02 Prospective changes. It is anticipated that the forthcoming proposed regulations would be prospective and would

not apply to taxable years beginning

before the issuance of final regulations.

SECTION 5. RELIANCE

.01 Interpretation of the post-OBBBA

definition of covered employee and limited

hours and nonexempt funds exceptions.

Until the forthcoming proposed regulations are issued, ATEOs may rely on the

rules described in section 4.01 of this

notice that are anticipated to be included

in the proposed regulations.

June 22, 2026

.02 Example.

Facts. ATEO 1 (an ATEO) and CORP 2 (a taxable-related organization) use a calendar taxable

year. Employees A and B have been employees of

CORP 2 and ATEO 1 since 2017. Employee A was a

covered employee for ATEO 1’s taxable year beginning on January 1, 2025, because Employee A was

one of ATEO 1’s five highest-compensated employees and did not qualify for an exception to such status for 2025. Employee B has never been one of the

five highest-compensated employees of ATEO 1 and

meets the requirements of the limited hours exception for ATEO 1’s taxable year beginning on January

1, 2026. Employee C has been an employee of CORP

2 since 2017 and was an employee of ATEO 1 only

in 2020, but not one of its five highest-compensated

employees because there were more than 5 individuals with higher remuneration than Employee C for

the 2020 taxable year.

Conclusion. Employee A is a covered employee

of ATEO 1 for taxable year 2026 because Employee

A was a covered employee for 2025 and covered

employee status, once obtained, is permanent.

In accordance with section 5.01 of this notice,

ATEO 1 may rely on the interpretation of the postOBBBA definition of covered employee described in

section 3 of this notice and the limited hours exception to determine that Employee B is not a covered

employee of ATEO 1 for taxable year 2026.

In accordance with section 5.01 of this

notice, ATEO 1 may rely on the interpretation of the post-OBBBA definition of covered

employee described in section 3 of this notice

to determine that Employee C is not a covered

employee of ATEO 1 for taxable year 2026 by

reason of being a former employee of ATEO

1. Although Employee C was an employee of

ATEO 1 in 2020, Employee C was not a covered employee for that taxable year under the

interpretation of the post-OBBBA definition of

covered employee described in section 3 of this

notice and thus was not a covered employee for

any taxable year through 2025 under prior law.

If Employee C becomes an employee of ATEO

1 in a post-2025 taxable year and does not meet

any applicable exception to covered employee

status, Employee C will be a covered employee

of ATEO 1 for that taxable year and all future

taxable years.

SECTION 6. REQUEST FOR

COMMENTS

The Treasury Department and the IRS

request comments regarding all issues

raised by this notice, in particular: (1)

any changes that are needed or appropriate to adapt the current limited hours and

nonexempt funds exceptions to the new

1588

definition of covered employee under

the OBBBA and the appropriateness of

applying these exceptions to officers of

the ATEO, and (2) any other issues that

should be addressed in the forthcoming

proposed regulations.

SECTION 7. SUBMISSION OF

COMMENTS

.01 Written comments should be submitted on or before August 4, 2026. Consideration will be given, however, to any

written comment submitted after such

date, if such consideration will not delay

the issuance of guidance. The subject line

for the comments should include a reference to Notice 2026-36. Comments may

be submitted in one of two ways:

(1) Electronically via the Federal

eRulemaking Portal at www.regulations.

gov (type IRS-2026-0233 in the search

field on the regulations.gov homepage to

find this notice and submit comments).

(2) Alternatively, by mail to: Internal

Revenue Service, CC:PA:01:PR (Notice

2026-36), Room 5503, P.O. Box 7604,

Ben Franklin Station, Washington, DC

20044.

.02 All commenters are strongly

encouraged to submit comments electronically. 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

www.regulations.gov.

SECTION 8. DRAFTING

INFORMATION

The principal authors of this notice are

Robert C. Weedman and Ward L. Thomas

of the Office of Associate Chief Counsel

(Employee Benefits, Exempt Organizations, and Employment Taxes). For further information regarding this notice,

contact Mr. Weedman at (202) 317-3517

or Mr. Thomas at (202) 317-6173 (not a

toll-free number).

Bulletin No. 2026–26

Credit for Renewable

Electricity Production and

Publication of Inflation

Adjustment Factor and

Reference Price for

Calendar Year 2026

Notice 2026-37

This notice publishes the inflation

adjustment factor and reference price for

calendar year 2026 for the renewable electricity production credit under section 45

of the Internal Revenue Code (section 45

credit). The 2026 inflation adjustment factor and reference price are used in determining the availability of the credit and

apply to calendar year 2026 sales of kilowatt hours of electricity produced in the

United States or a possession thereof from

qualified energy resources.

BACKGROUND

Section 45 was amended by section

13101 of Public Law 117-169, 136 Stat.

1818 (August 16, 2022), commonly

known as the Inflation Reduction Act of

2022 (IRA). The IRA changed the manner

in which the section 45 credit amounts are

calculated for any qualified facility placed

in service after December 31, 2021.

As amended by the IRA, section 45(b)

(6)(A) provides that, in the case of any

qualified facility that satisfies the requirements of section 45(b)(6)(B), the credit

amount determined under section 45(a)

(determined after the application of section 45(b)(1) through (5) and without

regard to section 45(b)(6)) is equal to

such amount multiplied by 5. A qualified

facility satisfies the requirements of section 45(b)(6)(B) if it is placed in service

after December 31, 2021, and it is one of

the following: (i) a facility with a maximum net output of less than 1 megawatt

(as measured in alternating current); (ii)

a facility the construction of which began

prior to January 29, 2023, which is the

date that is 60 days after the publication of

the guidance with respect to the requirements of section 45(b)(7)(A) (prevailing

wage requirements) and section 45(b)(8)

(apprenticeship requirements);1 or (iii) a

facility that satisfies the requirements of

section 45(b)(7)(A) and (8). The IRA also

added bonus credit amounts with respect

to qualified facilities placed in service after

December 31, 2022, that meet domestic

content requirements under section 45(b)

(9)2 or energy community requirements

under section 45(b)(11).3

The IRA amended the phaseout of the

section 45 credit for wind facilities under

section 45(b)(5) such that it does not apply

to facilities placed in service after December 31, 2021. The IRA also added a new

phaseout of the section 45 credit under

section 45(b)(10) in the case of qualified

facilities placed in service after December

31, 2022, for taxpayers making an elective payment election under section 6417.

The IRA also amended the credit amount

reduction under section 45(b)(3) in the

case of qualified facilities the construction

of which began after August 16, 2022.

The IRA amended section 45(d)(4) to

restore the section 45 credit for electricity produced in solar energy facilities in

the case of qualified facilities placed in

service after December 31, 2021, and the

construction of which began before January 1, 2025. Effective for facilities placed

in service after December 31, 2022, the

IRA (1) removed the one-half reduction

of the credit amount under section 45(b)

(4)(A) for qualified hydropower facilities

and marine and hydrokinetic renewable

energy facilities and (2) amended the definition of marine and hydrokinetic renewable energy under section 45(c)(10) and

the definition of a marine and hydrokinetic

renewable energy facility under section

45(d)(11). The IRA also extended certain

deadlines in the definitions under section

45(d) for wind facilities, closed-loop biomass facilities, open-loop biomass facilities, geothermal facilities, landfill gas

facilities, trash facilities, qualified hydro-

power facilities, and marine and hydrokinetic renewable energy facilities.

Section 45(a) provides that the renewable electricity production credit for any

tax year is an amount equal to the product

of the kilowatt hours of specified electricity produced by the taxpayer and sold to

an unrelated person during the tax year

multiplied by 1.5 cents (in the case of a

qualified facility placed in service before

January 1, 2022) or 0.3 cents (in the case

of a qualified facility placed in service

after December 31, 2021). This electricity

must be produced from qualified energy

resources and at a qualified facility during

the 10-year period beginning on the date

the facility was originally placed in service.

Section 45(b)(1) provides that the

amount of the credit determined under

section 45(a) is reduced by an amount

which bears the same ratio to the amount

of the credit as the amount by which the

reference price for the calendar year in

which the sale occurs exceeds 8 cents,

bears to 3 cents. Under section 45(b)(2),

the 1.5 cent (or 0.3 cent) amount in section 45(a) and the 8 cent amount in section

45(b)(1) are each adjusted by multiplying

such amount by the inflation adjustment

factor for the calendar year in which the

sale occurs. In the case of any qualified

facility placed in service before January

1, 2022, if any amount as increased under

section 45(b)(2) is not a multiple of 0.1

cent, such amount is rounded to the nearest multiple of 0.1 cent. In the case of any

qualified facility placed in service after

December 31, 2021, if the 0.3 cent amount

as increased under section 45(b)(2) is not

a multiple of 0.05 cent, such amount is

rounded to the nearest multiple of 0.05

cent.

In the case of electricity produced in

open-loop biomass facilities, landfill gas

facilities, trash facilities, qualified hydropower facilities, and, if placed in service before January 1, 2023, marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount in

effect under section 45(a)(1) for such cal-

See §§ 1.45-6, 1.45-7, 1.45-8, and 1.45-12 of the Income Tax Regulations for additional information regarding the requirements of section 45(b)(6)(B).

See Notice 2023-38, 2023-22 I.R.B. 872 (May 12, 2023), Notice 2024-41, 2024-24 I.R.B. 1615 (May 16, 2024), corrected at IR 2024-147 (May 24, 2024), and Notice 2025-08, 2025-8 I.R.B.

800 (February 18, 2025), for additional information regarding the domestic content bonus credit.

3

See Notice 2024-30, 2024-16 I.R.B. 878 (April 15, 2024), for additional information regarding the energy community bonus credit.

1

2

Bulletin No. 2026–26

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June 22, 2026

endar year (determined before rounding as

required by section 45(b)(2)) to be reduced

by one-half. As amended by the IRA, the

one-half reduction under section 45(b)(4)

(A) no longer applies to qualified hydropower facilities and marine and hydrokinetic renewable energy facilities placed in

service after December 31, 2022.

Section 45(b)(5) provides that in the

case of any qualified wind facility placed

in service before January 1, 2022, the

amount of the credit determined under

section 45(a) (determined after the application of section 45(b)(1), (2), and (3) and

without regard to section 45(b)(5)) shall

be reduced by (A) in the case of any facility the construction of which began after

December 31, 2016, and before January 1,

2018, 20 percent, (B) in the case of any

facility the construction of which began

after December 31, 2017, and before January 1, 2019, 40 percent, (C) in the case

of any facility the construction of which

began after December 31, 2018, and

before January 1, 2020, 60 percent, and

(D) in the case of any facility the construction of which began after December

31, 2019, and before January 1, 2022, 40

percent.

Section 45(c)(1) defines qualified

energy resources as wind, closed-loop

biomass, open-loop biomass, geothermal energy, solar energy, municipal solid

waste, qualified hydropower production,

and marine and hydrokinetic renewable

energy.

Section 45(d)(1) defines a qualified

facility using wind to produce electricity as any facility owned by the taxpayer

that was originally placed in service after

December 31, 1993, and the construction

of which began before January 1, 2025.

See section 45(e)(7) for rules relating to

the inapplicability of the credit to electricity sold to utilities under certain contracts.

Section 45(d)(2)(A) defines a qualified

facility using closed-loop biomass to produce electricity as any facility owned by

the taxpayer that was originally placed in

service after December 31, 1992, and the

construction of which began before January 1, 2025, or owned by the taxpayer

which before January 1, 2025, was originally placed in service and modified to use

closed-loop biomass to co-fire with coal,

with other biomass, or with both, but only

if the modification is approved under the

June 22, 2026

Biomass Power for Rural Development

Programs or is part of a pilot project of

the Commodity Credit Corporation as

described in 65 FR 63052. For purposes

of section 45(d)(2)(A)(ii), a facility shall

be treated as modified before January 1,

2025, if the construction of such modification began before such date. Section 45(d)

(2)(C) provides that in the case of a qualified facility described in section 45(d)(2)

(A)(ii), the 10-year period referred to in

section 45(a) is treated as beginning no

earlier than the date of the enactment of

section 45(d)(2)(C)(i) (October 22, 2004),

and if the owner of such facility is not the

producer of the electricity, the person eligible for the credit allowable under section

45(a) is the lessee or the operator of such

facility. A qualified facility using closedloop biomass includes a new unit placed

in service after the date of the enactment

of section 45(d)(2)(B) (October 3, 2008)

in connection with a qualified facility

using closed-loop biomass, but only to the

extent of the increased amount of electricity produced at the facility by reason of

such new unit.

Section 45(d)(3)(A) defines a qualified facility using open-loop biomass to

produce electricity as any facility owned

by the taxpayer which in the case of a

facility using agricultural livestock waste

nutrients, was originally placed in service

after the date of the enactment of section

45(d)(3)(A)(i)(I) (October 22, 2004) and

the construction of which began before

January 1, 2025, and the nameplate capacity rating of which is not less than 150

kilowatts, and in the case of any other

facility, the construction of which began

before January 1, 2025. In the case of any

facility described in section 45(d)(3)(A),

if the owner of such facility is not the producer of the electricity, section 45(d)(3)

(C) provides that the person eligible for

the credit allowable under section 45(a) is

the lessee or the operator of such facility.

A qualified facility using open-loop biomass includes a new unit placed in service

after the date of the enactment of section

45(d)(3)(B) (October 3, 2008) in connection with a qualified facility using openloop biomass, but only to the extent of the

increased amount of electricity produced

at the facility by reason of such new unit.

Section 45(d)(4) defines a qualified

facility using geothermal energy to pro-

1590

duce electricity as any facility owned by

the taxpayer that was originally placed in

service after the date of the enactment of

section 45(d)(4) (October 22, 2004) and

the construction of which began before

January 1, 2025. A qualified facility using

geothermal energy does not include any

property described in section 48(a)(3) the

basis of which is taken into account by the

taxpayer for purposes of determining the

energy credit under section 48.

As amended by the IRA and effective

for solar energy facilities placed in service

after December 31, 2021, section 45(d)(4)

also defines a qualified facility using solar

energy to produce electricity as any facility owned by the taxpayer that was originally placed in service after the date of the

enactment of section 45(d)(4) (October

22, 2004) and the construction of which

began before January 1, 2025. A qualified

facility using solar energy does not include

any property described in section 48(a)(3)

the basis of which is taken into account by

the taxpayer for purposes of determining

the energy credit under section 48.

Section 45(d)(6) defines a qualified

facility using gas derived from the biodegradation of municipal solid waste to

produce electricity as any facility owned

by the taxpayer that was originally placed

in service after the date of the enactment

of section 45(d)(6) (October 22, 2004) and

the construction of which began before

January 1, 2025.

Section 45(d)(7) defines a qualified

facility (other than a facility described in

section 45(d)(6)) that uses municipal solid

waste to produce electricity as any facility owned by the taxpayer that was originally placed in service after the date of the

enactment of section 45(d)(7) (October

22, 2004) and the construction of which

began before January 1, 2025. A qualified facility using municipal solid waste

includes a new unit placed in service in

connection with a facility placed in service on or before the date of the enactment

of section 45(d)(7), but only to the extent

of the increased amount of electricity produced at the facility by reason of such new

unit.

Section 45(d)(9) defines a qualified

facility producing qualified hydroelectric

production (as described in section 45(c)

(8)) as (i) any facility producing incremental hydropower production, but only to the

Bulletin No. 2026–26

extent of its incremental hydropower production attributable to efficiency improvements or additions to capacity described in

section 45(c)(8)(B) placed in service after

the date of the enactment of section 45(d)

(9) (August 8, 2005) and before January

1, 2025, and (ii) any other facility placed

in service after the date of the enactment

of section 45(d)(9) (August 8, 2005) and

the construction of which began before

January 1, 2025. Section 45(d)(9)(B) provides that, in the case of a qualified facility described in section 45(d)(9)(A), the

10-year period referred to in section 45(a)

shall be treated as beginning on the date

the efficiency improvements or additions

to capacity are placed in service. Section

45(d)(9)(C) provides that for purposes

of section 45(d)(9)(A)(i), an efficiency

improvement or addition to capacity shall

be treated as placed in service before January 1, 2025, if the construction of such

improvement or addition began before

such date.

As amended by the IRA, section 45(d)

(11) provides that, in the case of a facility producing electricity from marine

and hydrokinetic renewable energy, the

term “qualified facility” means any facility owned by the taxpayer which has a

nameplate capacity rating of at least 150

kilowatts (or at least 25 kilowatts in the

case of a facility placed in service after

December 31, 2022), and was originally

placed in service on or after the date of

the enactment of section 45(d)(11) (October 3, 2008) and the construction of which

began before January 1, 2025.

Section 45(e)(2)(A) requires the Secretary to determine and publish in the Federal Register each calendar year the inflation adjustment factor and the reference

price for such calendar year. The inflation

adjustment factor and the reference price

for the 2026 calendar year were published

in the Federal Register at 91 FR 32511 on

June 1, 2026.

Section 45(e)(2)(B) defines the inflation adjustment factor for a calendar year

as a fraction the numerator of which is the

GDP implicit price deflator for the preceding calendar year and the denominator

of which is the GDP implicit price deflator for the calendar year 1992. The term

“GDP implicit price deflator” means the

most recent revision of the implicit price

deflator for the gross domestic product as

computed and published by the Department of Commerce before March 15 of

the calendar year.

Section 45(e)(2)(C) provides that the

reference price with respect to a calendar

year is the Secretary’s determination of

the annual average contract price per kilowatt hour of electricity generated from the

same qualified energy resource and sold

in the previous year in the United States.

Only contracts entered into after December 31, 1989, are taken into account.

INFLATION ADJUSTMENT

FACTOR AND REFERENCE PRICE

The inflation adjustment factor for

calendar year 2026 for qualified energy

resources is 2.0570.

The reference price for calendar year

2026 for facilities producing electricity

from wind (based upon information provided by the Department of Energy) is

3.17 cents per kilowatt hour. The reference prices for facilities producing electricity from closed-loop biomass, openloop biomass, geothermal energy, solar

energy, municipal solid waste, qualified

hydropower production, and marine and

hydrokinetic renewable energy have not

been determined for calendar year 2026.

PHASEOUT CALCULATION

Because the 2026 reference price for

electricity produced from wind (3.17 cents

per kilowatt hour) does not exceed 8 cents

multiplied by the inflation adjustment factor (2.0570), the phaseout of the credit provided in section 45(b)(1) does not apply to

such electricity sold during calendar year

2026. However, section 45(b)(5) provides

an additional phaseout of the credit for

wind facilities placed in service before

January 1, 2022, and the construction of

which began after December 31, 2016.

For electricity produced from closed-loop

biomass, open-loop biomass, geothermal energy, solar energy, municipal solid

waste, qualified hydropower production,

and marine and hydrokinetic renewable

energy, the phaseout of the credit provided

in section 45(b)(1) does not apply to such

electricity sold during calendar year 2026.

CREDIT AMOUNT FOR A

QUALIFIED FACILITY PLACED

IN SERVICE BEFORE JANUARY 1,

2022

As required by section 45(b)(2), the 1.5

cent amount provided in section 45(a)(1)

is adjusted by multiplying such amount

by the inflation adjustment factor for the

calendar year in which the sale occurs.

If any amount as increased under section

45(b)(2) is not a multiple of 0.1 cent, such

amount is rounded to the nearest multiple of 0.1 cent. In the case of electricity

produced in open-loop biomass facilities,

landfill gas facilities, trash facilities, qualified hydropower facilities, and marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount in

effect under section 45(a)(1) for such calendar year (before rounding to the nearest

0.1 cent as required by section 45(b)(2)) to

be reduced by one-half.4

Under the calculation required by section 45(b)(2), the credit for renewable

electricity production for calendar year

2026 determined under section 45(a) is

3.1 cents per kilowatt hour on the sale of

electricity produced in any qualified facility placed in service before January 1,

2022, from the qualified energy resources

of wind, closed-loop biomass, and geothermal energy, and 1.5 cents per kilowatt

hour on the sale of electricity produced

in any qualified facility placed in service

before January 1, 2022, from the qualified

energy resources of open-loop biomass,

landfill gas, trash, qualified hydropower,

and marine and hydrokinetic renewable

energy.

CREDIT AMOUNT FOR A

QUALIFIED FACILITY PLACED IN

SERVICE AFTER DECEMBER 31,

2021

As required by section 45(b)(2), the 0.3

cent amount provided in section 45(a)(1)

is adjusted by multiplying such amount by

the inflation adjustment factor for the cal-

As amended by the IRA and discussed later in this notice, the one-half reduction under section 45(b)(4)(A) no longer applies to qualified hydropower facilities and marine and hydrokinetic

renewable energy facilities placed in service after December 31, 2022.

4

Bulletin No. 2026–26

1591

June 22, 2026

endar year in which the sale occurs. If the

0.3 cent amount as adjusted for inflation

is not a multiple of 0.05 cent, the amount

is rounded to the nearest multiple of 0.05

cent. In the case of electricity produced

in open-loop biomass facilities, landfill

gas facilities, trash facilities, qualified

hydropower facilities, and marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount

in effect under section 45(a)(1) for such

calendar year (determined before rounding as required by section 45(b)(2)) to be

reduced by one-half.

Under the calculation required by section 45(b)(2), the credit for renewable

electricity production for calendar year

2026 determined under section 45(a) is

0.6 cents per kilowatt hour on the sale of

electricity produced in any qualified facility placed in service after December 31,

2021, from the qualified energy resources

of wind, closed-loop biomass, geothermal

energy, and solar energy, and 0.3 cents

per kilowatt hour on the sale of electricity

June 22, 2026

produced in any qualified facility placed

in service after December 31, 2021, from

the qualified energy resources of openloop biomass, landfill gas and trash. The

credit for renewable electricity production for calendar year 2026 determined

under section 45(a) is also 0.3 cents per

kilowatt hour on the sale of electricity

produced in any qualified facility placed

in service after December 31, 2021, and

before January 1, 2023, from the qualified

energy resources of qualified hydropower

and marine and hydrokinetic renewable

energy.

ified hydropower facilities and marine

and hydrokinetic renewable energy facilities placed in service after December 31,

2022. Accordingly, under the calculation

required by section 45(b)(2), the credit

for renewable electricity production for

calendar year 2026 determined under section 45(a) is 0.6 cents per kilowatt hour

on the sale of electricity produced in any

qualified facility placed in service after

December 31, 2022, from the qualified

energy resources of qualified hydropower

and marine and hydrokinetic renewable

energy.

CREDIT AMOUNT FOR

QUALIFIED HYDROPOWER

FACILITIES AND MARINE AND

HYDROKINETIC RENEWABLE

ENERGY FACILITIES PLACED IN

SERVICE AFTER DECEMBER 31,

2022

DRAFTING AND CONTACT

INFORMATION

The one-half reduction under section

45(b)(4)(A) no longer applies to qual-

1592

The principal author of this notice

is Charles Hyde of the Office of Associate Chief Counsel (Energy, Credits,

and Excise Tax). For further information regarding this notice contact Mr.

Hyde at (202) 317-6853 (not a toll-free

number).

Bulletin No. 2026–26

Part IV

Notice of Proposed

Rulemaking

Estate Tax Closing Letter

User Fee Update

6859; concerning cost methodology, CFO

Cost and User Fees at (202) 317-6400;

concerning submissions of comments or

requests for a public hearing, the Publications and Regulations Section at (202) 3176901 (not toll-free numbers) or by email at

publichearings@irs.gov (preferred).

REG-103193-26

SUPPLEMENTARY INFORMATION:

AGENCY: Internal Revenue Service

(IRS), Treasury.

Authority

ACTION: Notice of proposed rulemaking.

SUMMARY: This document contains proposed regulations amending the current

regulations to increase the amount of the

user fee imposed on authorized persons

requesting the issuance of an estate tax closing letter. The Independent Offices Appropriations Act of 1952 authorizes charging

user fees in appropriate circumstances. The

proposed regulations would affect persons

who request an estate tax closing letter.

DATES: Written or electronic comments

and requests for a public hearing must be

received by July 2, 2026.

ADDRESSES: Commenters are strongly

encouraged to submit public comments

electronically. Submit electronic submissions via the Federal eRulemaking Portal

at https://www.regulations.gov (indicate

IRS and REG-103193-26) by following

the online instructions for submitting comments. Requests for a public hearing must be

submitted as prescribed in the “Comments

and Request for Public Hearing” section.

Once submitted to the Federal eRulemaking Portal, comments cannot be edited or

withdrawn. The Department of the Treasury

(Treasury Department) and the IRS will

publish for public availability any comments

submitted to the IRS’s public docket. Send

paper submissions to: CC:PA:01:PR (REG103193-26), Room 5503, Internal Revenue

Service, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044.

FOR FURTHER INFORMATION

CONTACT: Concerning the proposed

regulations, Juli Ro Kim at (202) 317-

Bulletin No. 2026–26

This notice of proposed rulemaking

proposes amendments to 26 CFR part 300

regarding user fees for authorized persons

who request the issuance of an estate tax

closing letter (also referred to as the IRS

Letter 627).

The Independent Offices Appropriations Act of 1952 (IOAA) (31 U.S.C.

9701) authorizes each agency to prescribe regulations that establish user fees

for services provided by the agency. The

IOAA provides that regulations implementing user fees are subject to policies

prescribed by the President; these policies

are set forth in the Office of Management

and Budget Circular A-25, 58 FR 38142

(July 15, 1993) (OMB Circular A-25).

The IOAA states that the services provided by an agency should be self-sustaining to the extent possible. Under OMB

Circular A-25, agencies that provide services that confer special benefits on identifiable recipients beyond those accruing to

the general public must identify those services, determine whether user fees should

be assessed for those services, and, if so,

establish user fees that recover the full

cost of providing those services, unless

an exception to the full cost requirement

is granted. As required by the IOAA and

OMB Circular A-25, agencies are to

review user fees biennially and update

them as necessary to reflect changes in the

cost of providing the underlying services.

Background and Explanation of

Provisions

A. Estate Tax Closing Letter User Fee

On September 28, 2021, the Treasury

Department and the IRS published final

1593

regulations (TD 9957) in the Federal

Register (86 FR 53539) establishing a $67

user fee to apply to requests for the issuance of an estate tax closing letter, based

on a 2019 Cost Model. Based on a 2023

Cost Model, the Treasury Department and

the IRS published in the Federal Register an interim final rule (TD 10031, 90

FR 21410) on May 20, 2025, followed by

final regulations adopting the interim final

rule (TD 10038, 90 FR 55041) on December 1, 2025, which established the current

$56 user fee to apply to requests for the

issuance of an estate tax closing letter.

As explained in the Background section of the preamble of TD 9957, the

issuance of an estate tax closing letter

constitutes the provision of a service and

confers special benefits to authorized persons requesting such letters beyond those

accruing to the general public. Therefore,

the IRS is authorized, pursuant to the

IOAA and OMB Circular A-25, to charge

a user fee for the issuance of an estate tax

closing letter that reflects the full cost of

providing this service.

In 2025, the IRS conducted a biennial

review of the estate tax closing letter user

fee and issued a new Cost Model, which

determined that the full cost of issuing

estate tax closing letters to authorized persons is $76. The increase is due to a combination of operational factors.

B. Calculation of User Fees Generally

The IRS follows generally accepted

accounting principles (GAAP) in calculating the full cost of providing services.

The Federal Accounting Standards Advisory Board (FASAB) is the body that

establishes GAAP that apply for Federal reporting entities such as the IRS.

FASAB publishes the FASAB Handbook

of Accounting Standards and Other Pronouncements, as amended, available at

https://fasab.gov/accounting-standards/.

The FASAB Handbook includes the Statement of Federal Financial Accounting

Standards 4: Managerial Cost Accounting

Standards and Concepts (SFFAS No. 4)

for the Federal government. SFFAS No.

4 establishes internal costing standards

under GAAP to accurately measure and

June 22, 2026

manage the full cost of Federal programs.

The methodology described below is in

accordance with SFFAS No. 4.

1. Cost Center Allocation

The IRS determines the cost of its

services and the activities involved in

producing them through a cost accounting system that tracks costs to organizational units. The lowest organizational

unit in the IRS’s cost accounting system

is a cost center. Cost centers usually are

separate offices that are distinguished by

subject-matter area of responsibility or

geographic region. All costs of operating

a cost center are recorded in the IRS’s

cost accounting system and are allocated

to that cost center. These costs include the

direct costs for the cost center’s activities

and all indirect costs, including overhead,

associated with that cost center. Each cost

is recorded in only one cost center.

2. Cost Estimation of Direct Labor and

Benefits

Not all cost centers are fully devoted

to only one service for which the IRS

charges a user fee. When cost centers

include multiple services, the IRS measures the time required to accomplish

activities associated with each service to

estimate the average time spent on the service in the related cost center. The average

time devoted is multiplied by the relevant

organizational unit’s average labor and

benefits cost per unit of time to determine

the direct labor and benefits cost incurred

to provide the service. To determine the

full cost, the IRS then adds an appropriate

overhead charge.

rate, based on FY 2024 costs, of 62.92

percent was used.

3. Calculating Overhead

C. Full Cost Determination for the

Estate Tax Closing Letter User Fee

Overhead is an indirect cost of operating

an organization that cannot be immediately

associated with an activity that the organization performs. Overhead includes costs of

resources that are jointly or commonly consumed by one or more organizational unit’s

activities but are not specifically identifiable

to a single activity, such as the following:

• General management and administration

• Rent, security, utilities and maintenance

• Procurement and contracting

• Financial management and accounting

• Information technology

• Research, analytical, and statistical

• Human resources and personnel

To calculate the overhead allocable to

a service, the IRS multiplies the current

overhead rate by the direct labor and benefits costs of the service. The overhead rate

is the ratio of the IRS’s indirect labor, benefits, and non-labor costs of business divisions that do not interact with taxpayers to

the direct labor and benefits costs of business divisions that interact with taxpayers. The IRS calculates the overhead rate

annually based on cost elements underlying the Statement of Net Cost included

in the IRS Annual Financial Statements,

which are audited by the Government

Accountability Office.

For this estate tax closing letter user fee

review, the fiscal year (FY) 2025 overhead

Direct Staff Hours

Indirect Hours (60%)

Total Hours

To determine the labor and benefits

costs, the IRS divided the 8,374 total hours

by 2,080 (the total annual hours worked

by a full-time employee (FTE)) to convert

the hours to a 4.03 FTE equivalent. The

processing of requests for estate tax clos-

1. Request Processing Costs

Requests for estate tax closing letters

are processed by employees at grades 5,

8, and 11 of the general schedule (GS-5,

GS-8, and GS-11). Approximately 0.65

staff hours are required to review the

return, create the estate tax closing letters, and prepare the letters for mailing.

The IRS processed an average of 8,053

requests per year for estate tax closing letters in FY 2023 and FY 2024, requiring

5,234 staff hours.

Total hours allocated to the cost also

must include indirect hours for campus employees, which are calculated

by multiplying the direct hours by the

applicable 60 percent indirect employee

rate. Using this information, IRS determined that staff hours for processing

requests for estate tax closing letters are

8,374 annually.

5,234

+  3,140

8,374

ing letters is performed at the GS-5 level

(36.85 percent), but also by employees at

the GS‑8 level (35.82 percent) and GS-11

level (27.33 percent). The average salary

and benefit cost for each of those levels

was multiplied by that grade’s percentage

Total Cost Per FTE

Total FTE

Processing Labor & Benefits

June 22, 2026

The IRS followed the guidance provided by the OMB Circular A-25 guidance to compute the full cost of issuing

estate tax closing letters to authorized

persons. OMB Circular A-25 explains that

the full cost includes all indirect and direct

costs to any part of the Federal Government including, but not limited to, direct

and indirect personnel costs, physical

overhead, rents, utilities, travel, and management costs.

of processing time to arrive at a $92,812

total cost per FTE. Multiplying the cost

per FTE by the 4.03 FTE equivalent

resulted in a total labor and benefits cost

of $374,032, as follows:

$92,812

×   4.03

$374,032

1594

Bulletin No. 2026–26

2. Quality Assurance Review Costs

A sampling of issued estate tax closing letters are reviewed to verify (1) the

estate tax closing letter was authorized,

(2) the information included in the estate

tax closing letter was accurate, and (3) the

address was correct.

During FY 2023 and FY 2024, 48

estates were issued estate tax closing

letters (an annual average of 24 estates)

that were reviewed for quality assurance

purposes. Generally, three letters are

reviewed per estate and quality assurance

professionals spend 0.5 hours reviewing

one estate tax closing letter, totaling 36

Direct Staff Hours

Indirect Hours (60%)

Total Hours

Outgoing estate tax closing letters are

reviewed by quality assurance professionals at the following Internal Revenue (IR)

paybands of the IRS Payband System:

IR-10 (25 percent) and IR-06 (75 percent).

direct staff hours. The direct staff hours

were multiplied by the 60 percent indirect employee rate for campus employees,

resulting in a combined total of 58 annual

staff hours allocated for quality assurance

(QA) reviews, as follows:

36

+  22

58

Dividing the total hours by 2,080 (the total

annual hours for each FTE) resulted in 0.03

FTEs. The average salary and benefits for

both IR paybands conducting QA reviews

was multiplied by that IR payband’s per-

Total Cost per FTE

Total FTE

Quality Assurance Labor & Benefits

centage of processing time to arrive at the

$3,818 total cost per FTE. The total cost

per FTE was then multiplied by the total

FTE to determine the labor and benefits

cost for QA reviews, as follows:

$127,256

×   0.03

$3,818

3. Full Cost Per Request Calculation

The IRS applied the 62.92 percent overhead rate to the total labor and benefits cost to calculate the full cost of the estate tax closing

letter program.

Processing Labor & Benefits

Quality Assurance Labor & Benefits

Total Labor and Benefits

Overhead (62.92%)

Full Cost

$374,032

+  $3,818

$377,850

+ $237,743

$615,593

The $76 cost per request was determined by dividing the full cost by the average annual volume of processed requests, as follows:

Full Cost

Estimated Annual Request Volume

Cost Per Request

$615,593

÷  8,053

$76

Proposed Applicability Date

Special Analyses

II. Regulatory Flexibility Act

These regulations are proposed to

apply to requests for an estate tax closing letter received by the IRS on or

after the date that is 30 days after the

date these regulations are published as

final regulations in the Federal Register.

I. Regulatory Planning and Review

Pursuant to the Regulatory Flexibility

Act (5 U.S.C. chapter 6), it is hereby certified that these proposed regulations will

not have a significant economic impact

on a substantial number of small entities.

The proposed regulations, which would

increase the amount of a fee to obtain a

Bulletin No. 2026–26

The OMB’s Office of Information and

Regulatory Analysis has determined that

this regulation is not significant and is not

subject to review under section 6(b) of

Executive Order 12866.

1595

June 22, 2026

particular service, would affect decedents’

estates, which generally are not “small

entities” as defined under 5 U.S.C. 601(6).

Thus, these proposed regulations would

have no economic impact on small entities. Accordingly, the Secretary certifies

that the rule will not have a significant

economic impact on a substantial number

of small entities.

III. Submission to Small Business

Administration

Pursuant to section 7805(f) of the

Internal Revenue Code, this notice of

proposed rulemaking has been submitted to the Chief Counsel of the Office of

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

small business.

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 proposed regulations do

not have federalism implications and do

not impose substantial direct compliance

costs on State and local governments or

preempt State law within the meaning of

the Executive order.

ever, other personnel from the Treasury

Department and the IRS participated in

their development.

Comments and Request for Public

Hearing

Accordingly, the Treasury Department

and the IRS propose to amend 26 CFR

part 300 as follows:

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. This

rule does 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.

Before these proposed regulations

are adopted as final regulations, consideration will be given to comments that

are submitted timely to the Treasury

Department and the IRS as prescribed in

this preamble under the ADDRESSES

heading. The Treasury Department and

IRS request comments on all aspects

of the proposed regulations. Any electronic and paper comments submitted

will be made available at https://www.

regulations.gov or upon request. Once

submitted to the Federal eRulemaking

Portal, comments cannot be edited or

withdrawn.

A public hearing will be scheduled if

requested in writing by any person that

timely submits written or electronic comments. If a public hearing is scheduled,

notice of the date, time, and place for the

public hearing will be published in the

Federal Register.

V. Executive Order 13132: Federalism

Drafting Information

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

The principal author of these proposed regulations is Juli Ro Kim of the

Office of the Associate Chief Counsel

(Passthroughs, Trusts, and Estates). How-

IV. Unfunded Mandates Reform Act

June 22, 2026

1596

List of Subjects in 26 CFR Part 300

Estate taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the

Regulations

PART 300--USER FEES

Paragraph 1. The authority citation

for part 300 continues to read, in part, as

follows:

Authority: 31 U.S.C. 9701.

Par. 2. Section 300.12 is amended by

revising paragraphs (b) and (d) to read as

follows:

§ 300.12 Fee for estate tax closing

letter.

*****

(b) Fee. The fee for issuing an estate

tax closing letter is $76.

*****

(d) Applicability date. This section

applies to requests received by the IRS on

or after [the date 30 days after the date of

publication of final regulations in the Federal Register].

Frank J. Bisignano,

Chief Executive Officer.

(Filed by the Office of the Federal Register June 1,

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

Federal Register for June 2, 2026, 91 FR 32909)

Bulletin No. 2026–26

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. 2026–26

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.

June 22, 2026

Numerical Finding List1

Bulletin 2026–26

Announcements:

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

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

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

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

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

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

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

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

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

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

AOD:

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

Notices:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2026-33, 2026-24 I.R.B. 1572

2026-32, 2026-25 I.R.B. 1578

2026-35, 2026-25 I.R.B. 1580

2026-36, 2026-26 I.R.B. 1587

2026-37, 2026-26 I.R.B. 1589

Proposed Regulations:

Revenue Rulings:—Continued

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

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

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

2026-03 I.R.B. 358

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

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

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

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

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

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

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

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

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

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

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

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

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

CC-00349656-26, 2026-25 I.R.B. 1583

REG-103193-26, 2026-26 I.R.B. 1593

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

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

2026-11, 2026-24 I.R.B. 1570

Treasury Decisions:

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

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

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

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

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

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

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

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

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

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

Revenue Procedures:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2026-24, 2026-25 I.R.B. 1582

Revenue Rulings:

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

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

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

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

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

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

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

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

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

2024–52, dated December 22, 2024.

1

June 22, 2026

ii

Bulletin No. 2026–26

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–26

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

2024–52, dated December 22, 2024.

1

Bulletin No. 2026–26

iii

June 22, 2026

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

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