Bulletin No. 2026–25

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2026–25

June 15, 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

Rev. Proc. 2026-24, page 1582.

Revenue Procedure 2026-24 provides the 2027 inflation

adjusted amounts for Health Savings Accounts (HSAs) as

determined under section 223 of the Internal Revenue Code

(Code) and the maximum amount that may be made newly

available for excepted benefit health reimbursement arrangements (HRAs) provided under § 54.9831-1(c)(3)(viii) of the

Pension Excise Tax Regulations.

EMPLOYEE PLANS

Notice 2026-32, page 1578.

This notice provides that a broker-dealer that carries customer accounts and receives or holds funds or securities

for those customers may, in lieu of demonstrating satisfaction of the adequacy of net worth requirement for nonbank

trustees under § 1.408-2(e)(5)(ii), demonstrate satisfaction

of Rule 15c3-1 (SEC Net Capital Rule) and Rule 15c3-3 (SEC

Finding Lists begin on page ii.

Customer Protection Rule) under the Securities Exchange

Act of 1934.

INCOME TAX

CC-00349656-26, page 1583.

These proposed regulations would withdraw applicability

dates and propose new applicability dates relating to proposed regulations under section 892 of the Internal Revenue Code for determining whether an acquisition of debt by

a foreign government is commercial activity and whether a

foreign government has effective control of an entity. These

proposed regulations would provide transitional relief to

existing holdings of foreign governments when finalized.

Notice 2026-35, page 1580.

This notice publishes the applicable percentage under §

613A(c)(6)(C) of the Internal Revenue Code for calendar

year 2026. The applicable percentage is used in computing

the allowance for depletion under § 611 for oil and natural

gas produced from marginal properties.

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 15, 2026 

Bulletin No. 2026–25

Part III

Alternative Method for

Carrying Broker-Dealers

to Comply with Certain

Nonbank Trustee Rules

Notice 2026-32

I. PURPOSE

This notice provides that, pursuant

to § 1.408-2(e)(6)(ii) of the Income Tax

Regulations, a broker-dealer that carries

customer accounts and receives or holds

funds or securities for those customers

(a carrying broker-dealer) may, in lieu of

demonstrating satisfaction of the adequacy

of net worth requirement for nonbank

trustees under § 1.408-2(e)(5)(ii), demonstrate satisfaction of Rule 15c3-1 (SEC

Net Capital Rule) and Rule 15c3-3 (SEC

Customer Protection Rule) (together, SEC

Net Capital and Customer Protection

Rules) of the Securities Exchange Act of

1934, as amended (Exchange Act).1 This

notice also describes procedures regarding

demonstration by a carrying broker-dealer

of satisfaction of the SEC Net Capital and

Customer Protection Rules and requests

public comments on related topics.2

II. BACKGROUND

A. Background on IRS Nonbank Trustee

Rules

Section 408(a) of the Internal Revenue

Code provides that an individual retirement

account (IRA) is a trust created or organized

in the United States for the exclusive benefit of an individual or the individual’s beneficiaries, but only if the written governing

instrument creating the trust meets certain

requirements. One such requirement, under

section 408(a)(2), is that the trustee of an

IRA must be a bank (as defined in section

408(n)) or “such other person who demonstrates to the satisfaction of the Secretary

that the manner in which such other person

will administer the trust will be consistent

with the requirements of this section.”3

In order for an entity that is not a bank to

qualify as an IRA trustee (i.e., a nonbank

trustee), § 1.408-2(e) imposes several

requirements, including fiduciary conduct

requirements.4

Section 1.408-2(e)(2) requires that

an applicant for nonbank trustee status

demonstrate its ability to act within the

accepted rules of fiduciary conduct by

including in its demonstration certain elements of proof. Under § 1.408-2(e)(2)(iv),

one of these required elements of proof is

to assure compliance with the fiduciary

conduct provisions set out in § 1.408-2(e)

(5). Under § 1.408-2(e)(5), the applicant

must demonstrate that, under applicable

regulatory requirements, corporate or

other governing instruments, or its established operating procedures, it satisfies

certain rules of fiduciary conduct, including the adequacy of net worth requirement

under § 1.408-2(e)(5)(ii).5 To comply with

this requirement, a nonbank trustee’s net

worth generally must exceed the greater

of (i) a specified dollar amount or (ii) a

percentage of the value of all assets held

in fiduciary accounts. However, that percentage test is modified under § 1.4082(e)(5)(ii)(D) in the case of a nonbank

trustee that is a member of the Securities

Investor Protection Corporation (SIPC).

A key objective of this adequacy of net

worth requirement is to ensure that nonbank trustees maintain a level of solvency

commensurate with their financial and

fiduciary responsibilities.6

Section 1.408-2(e) provides flexibility

for the Internal Revenue Service (IRS) to

apply the nonbank trustee requirements

under certain circumstances involving

overlapping regulatory requirements. Specifically, § 1.408-2(e)(6)(ii) provides that

“[e]vidence that an applicant is subject to

Federal or State regulation with respect to

one or more relevant factors shall be given

weight in proportion to the extent that

such regulatory standards are consonant

with the requirements of section [408]”7

and such evidence may be submitted “in

addition to, or in lieu of,” the specific

proofs required by § 1.408-2(e).

B. Background on Exchange Act Rules

15c3-1 and 15c3-38

Carrying broker-dealers are subject

to prescriptive regulation by the Securities and Exchange Commission (SEC),

including rules that aim to ensure carrying broker-dealers maintain a level

of solvency commensurate with their

financial responsibilities. The SEC Customer Protection Rule, as codified by the

SEC in 17 CFR 240.15c3-3, is designed

to give specific protection to customer

funds and securities (for example, IRA

assets), in effect forbidding carrying broker-dealers from using customer assets to

finance any part of their business unrelated to servicing securities customers.

To meet this objective, the SEC Customer Protection Rule requires a carrying

broker-dealer to take two primary steps

to safeguard customer assets, which are

designed to protect customers by segregating their securities and cash from

the carrying broker-dealer’s proprietary

business activities.

The first step to safeguard customer

assets under the SEC Customer Protec-

Pub. L. 73-291, 48 Stat. 881.

The guidance in this notice does not apply to a broker-dealer that operates pursuant to an exemption report under SEC Rule 17a-5(d) (17 CFR § 240.17a-5).

3

Nonbank trustees can be approved by the IRS to hold certain other types of fiduciary accounts, such as certain custodial accounts, Trump accounts, and health savings accounts. See section

3.07 of Rev. Proc. 2026-4, 2026-1 IRB 160 (updated annually).

4

The nonbank trustee rules also apply with respect to IRAs that are custodial accounts. See section 408(h) and § 1.408-2(d).

5

Under § 1.408-2(e)(5)(viii)(F), the term “net worth” is defined as “the amount of the applicant’s assets less the amount of its liabilities, as determined in accordance with generally accepted

accounting principles.”

6

See T.D. 8635, 60 Fed. Reg. 65547, 65548 (Dec. 20, 1995).

7

The final regulation points to section 401 (i.e., rules for qualification of employer-sponsored retirement plans); however, the reference is an artifact of the regulation’s original publication as

part of the regulations under section 401 and, thus, should be read as referring to section 408, which contains the IRA requirements.

8

Personnel from the Department of the Treasury (Treasury Department) and the IRS consulted with SEC staff in developing the description of the SEC Net Capital and Customer Protection

Rules discussed in this section, and that description was reviewed by SEC staff.

1

2

June 15, 2026

1578

Bulletin No. 2026–25

tion Rule requires carrying broker-dealers to maintain physical possession or

control over customers’ fully paid and

excess ­

margin securities.9 The second

step requires that a carrying broker-dealer

maintain a reserve of cash or qualified

securities in an account at a third-party

bank that is at least equal in value to the

net cash owed to customers, including

cash obtained from the use of customer

securities, determined by a computation

of the broker-dealer’s customer credit

items (for example, cash in customer

securities accounts and cash obtained

through the use of customer margin securities) subtracted by the broker-dealer’s

customer debit items (for example, margin

loans). If credit items exceed debit items,

the net amount must be on deposit in the

customer reserve bank account in the form

of cash and/or qualified securities. Subject to certain exceptions, the SEC Customer Protection Rule requires a carrying

broker-dealer to make this calculation of

the required deposit amount on a weekly

basis.

The SEC Customer Protection Rule

operates in tandem with the SEC Net Capital Rule, as codified in 17 CFR 240.15c31. The SEC Net Capital Rule is designed

to prevent a broker-dealer’s insolvency

by preventing excessive credit or market risk positions. Among other requirements, a broker-dealer must maintain a

minimum level of net capital under the

rules of 17 CFR 240.15c3-1 at all times,

and not be “insolvent” as defined in that

rule.10 The SEC has explained that “[t]he

objective of Rule 15c3-1 is to require a

broker-dealer to maintain sufficient liquid assets to meet all liabilities, including

obligations to customers, counterparties,

and other creditors and to have adequate

additional resources to wind-down its

business in an orderly manner without

the need for a formal proceeding if the

firm fails financially.”11

Pursuant to the Securities Investor

Protection Act of 1970 (SIPA),12 carrying

broker-dealers are required to be members of SIPC, which generally protects

each customer of a failed SIPC-member

broker-dealer up to $500,000, including

up to $250,000 for cash claims. The SEC

Customer Protection Rule supports SIPA’s

customer-protection objective by requiring carrying broker-dealers to segregate

customers’ securities and cash from the

broker-dealer’s proprietary business activities. Through this requirement, the SEC

Customer Protection Rule is designed to

ensure that, if the carrying broker-dealer

fails financially, the customer securities

and cash should be readily available to be

returned to customers, which facilitates

an orderly self-liquidation. However, if

the failed carrying broker-dealer is liquidated under SIPA, the customer securities

and cash should be isolated and readily

identifiable as “customer property” and,

consequently, available to be distributed

to customers ahead of other creditors.13 In

addition, the Financial Industry Regulatory Authority (FINRA), acting as the designated examining authority for carrying

broker-dealers, examines carrying broker-dealers’ compliance with the SEC’s

financial responsibility rules, including

the SEC Net Capital and Customer Protection Rules.

III. GUIDANCE

Stakeholders have asked the Department of the Treasury (Treasury Department) and the IRS whether, for purposes

of compliance with the nonbank trustee

fiduciary conduct requirements under

§ 1.408-2(e)(5), the regulatory standards

imposed on carrying broker-dealers by the

SEC Net Capital and Customer Protection

Rules are consonant with the adequacy of

net worth requirement under § 1.408-2(e)

(5)(ii), so that, under § 1.408-2(e)(6)(ii),

evidence of satisfaction of the SEC Net

Capital and Customer Protection Rules

by a carrying broker-dealer could be submitted to the IRS in lieu of evidence of

satisfaction of the adequacy of net worth

requirement.

A. Carrying Broker-Dealers May

Demonstrate Satisfaction of the SEC Net

Capital and Customer Protection Rules

in Lieu of the Adequacy of Net Worth

Requirement

The SEC Net Capital and Customer Protection Rules address the same core financial responsibility concerns reflected in the

adequacy of net worth requirement under

§ 1.408-2(e)(5)(ii), including the solvency

of an entity holding customer accounts

and the protection of customer accounts.

In addition, carrying broker-dealers subject to the SEC Net Capital and Customer

Protection Rules are subject to substantial

oversight, including by FINRA. Accordingly, for carrying broker-dealers, the

SEC Net Capital and Customer Protection

Rules are consonant with the adequacy

of net worth requirement under § 1.4082(e)(5)(ii). Thus, pursuant to § 1.4082(e)(6)(ii), a carrying broker-dealer may

demonstrate satisfaction of the SEC Net

Capital and Customer Protection Rules

in lieu of demonstrating satisfaction of

the adequacy of net worth requirement

for nonbank trustees under § 1.408-2(e)

(5)(ii). This alternative demonstration

is not available to a broker-dealer that

operates pursuant to an exemption report

under SEC Rule 17a-5(d). Comments are

requested on circumstances under which a

carrying broker-dealer that has indicated it

9

“Control” means the carrying broker-dealer holds these securities in one of several locations specified in SEC Exchange Act Rule 15c3-3 and free of liens or any other interest that could be

exercised by a third-party to secure an obligation of the carrying broker-dealer. See 17 CFR 240.15c3-3(c). Permissible locations include a clearing corporation and a “bank,” as defined in

section 3(a)(6) of the Exchange Act. A carrying broker-dealer does not treat customer securities as its own assets. Rather, the carrying broker-dealer holds them in a custodial capacity, and the

possession and control requirement is designed to ensure that the carrying broker-dealer treats them in a manner that allows for their prompt return.

10

For this purpose, “net capital” is defined in SEC Exchange Act Rule 15c3-1(c)(2) as “the net worth of a broker or dealer, adjusted by” deductions for certain illiquid assets along with certain

percentages from its proprietary securities or commodities inventory (for example, a 100% haircut for “non-marketable” securities and a 20% haircut for commodities), and additions back of

certain liabilities to arrive at net capital. One such “add-back” adjustment is for “liabilities of the broker or dealer which are subordinated to the claims of creditors pursuant to a satisfactory

subordination agreement.”

11

See 84 FR 43872, 43879 (Aug. 22, 2019).

12

Pub. L. 91-598, 84 Stat. 1636, codified at 15 U.S.C. § 78aaa et seq.

13

Of the approximately 770,400 claims satisfied in completed liquidations of broker-dealers under SIPA, as of December 31, 2025, a total of 355 were for cash and securities whose value was

greater than the limits of protection afforded by SIPA. The 355 claims represent less than one percent of all claims satisfied. The unsatisfied portion of claims, $49.7 million, represents less

than one percent of the total value of securities and cash distributed for accounts of customers in the 329 completed cases. See 2025 SIPC Annual Report.

Bulletin No. 2026–25

1579

June 15, 2026

is satisfying the SEC Net Capital and Customer Protection Rules would be treated

as no longer satisfying those rules and,

therefore, would no longer be eligible to

demonstrate satisfaction of the SEC Net

Capital and Customer Protection Rules in

lieu of the adequacy of net worth requirement.

B. Procedures for Existing Nonbank

Trustees That Are Carrying BrokerDealers

A carrying broker-dealer that has

received a nonbank trustee notice of

approval from the IRS based on satisfaction of the adequacy of net worth requirement of § 1.408-2(e)(5)(ii) and would like

to demonstrate satisfaction of the SEC Net

Capital and Customer Protection Rules in

lieu of the adequacy of net worth requirement must notify the IRS in accordance

with § 1.408-2(e)(6)(iv).

C. Procedures for Nonbank Trustee

Applicants That Are Carrying BrokerDealers

The procedures for applying to the

IRS to become a nonbank trustee are

described in Rev. Proc. 2026-4 (updated

annually). The Treasury Department and

the IRS anticipate updating the procedures for nonbank trustee applicants that

are carrying broker-dealers that want to

demonstrate satisfaction of the SEC Net

Capital and Customer Protection Rules

in lieu of the adequacy of net worth

requirement. Until the procedures are

updated, applicants may demonstrate

satisfaction of the SEC Net Capital and

Customer Protection Rules by applying

a reasonable, good faith interpretation of

this notice and Rev. Proc. 2026-4. Comments are requested on how these procedures should be updated, including what

documentation a carrying broker-dealer

should be required to submit with its

application to demonstrate satisfaction of

the SEC Net Capital and Customer Protection Rules, such as the carrying broker-dealer’s most recent: (1) Financial

and Operational Combined Uniform Single Report (“FOCUS Report”), Part II;

and (2) audited annual report including

a facing page (Form X-17A-5 Part III),

June 15, 2026

statement of financial condition, statement of income, net capital computation,

statement of cash flows, statement of

changes in stockholders’ or sole proprietor’s equity, statement of changes in liabilities subordinated to claims of general

creditors, and compliance report.

IV. APPLICABILITY DATE

This notice applies as of May 21, 2026.

V. REQUEST FOR COMMENTS

The Treasury Department and the

IRS request comments as described in

section III of this notice. Written comments should be submitted by July 20,

2026. The subject line for the comments should include a reference to

Notice 2026-32. Comments may be

submitted electronically via the Federal eRulemaking Portal at https://www.

regulations.gov (type IRS-2026-0628 in

the search field on the regulations.gov

homepage to find this notice and submit

comments). Alternatively, comments

may be submitted by mail to: Internal

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

2026-32), Room 5503, P.O. Box 7604,

Ben Franklin Station, Washington, DC

20044. 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 https://www.regulations.gov.

VI. PAPERWORK REDUCTION ACT

The Paperwork Reduction Act of 1995

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

requires that a Federal agency obtain

approval from the Office of Management and Budget (OMB) before collecting information from the public, whether

such collection 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 OMB control number.

This notice does not impose any new

reporting, recordkeeping, or third-party

disclosure requirements. Section III of

1580

this notice describes procedures for existing nonbank trustees that are carrying

broker-dealers, as well as procedures for

nonbank trustee applicants that are carrying broker-dealers under existing regulations (§ 1.408-2(e)(6)(iv)) and Rev. Proc.

2026-4. These requirements are already

approved under OMB Control Numbers

1545-0930 and 1545-1520.

VII. DRAFTING INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

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

please contact (202) 317-6000 (not a tollfree number).

2026 Marginal Production

Rates

Notice 2026-35

This notice announces the applicable

percentage under § 613A of the Internal

Revenue Code to be used in determining

percentage depletion for marginal properties for the 2026 calendar year.

Section 613A(c)(6)(C) defines the term

“applicable percentage” for purposes of

determining percentage depletion for oil

and gas produced from marginal properties. The applicable percentage is the

percentage (not greater than 25 percent)

equal to the sum of 15 percent, plus one

percentage point for each whole dollar

by which $20 exceeds the reference price

(determined under § 45K(d)(2)(C)) for

crude oil for the calendar year preceding

the calendar year in which the taxable year

begins. The reference price determined

under § 45K(d)(2)(C) for the 2025 calendar year is $63.40. Accordingly, 15% is

the applicable percentage under § 613A to

be used in determining percentage depletion for marginal properties for the 2026

calendar year.

The following table contains the applicable percentages for marginal production

for taxable years beginning in calendar

years 1991 through 2026.

Bulletin No. 2026–25

Applicable Percentage for Marginal Production

Calendar Year

Applicable Percentage

1991

15 percent

1992

18 percent

1993

19 percent

1994

20 percent

1995

21 percent

1996

20 percent

1997

16 percent

1998

17 percent

1999

24 percent

2000

19 percent

2001

15 percent

2002

15 percent

2003

15 percent

2004

15 percent

2005

15 percent

2006

15 percent

2007

15 percent

2008

15 percent

2009

15 percent

2010

15 percent

2011

15 percent

2012

15 percent

2013

15 percent

2014

15 percent

2015

15 percent

2016

15 percent

2017

15 percent

2018

15 percent

2019

15 percent

2020

15 percent

2021

15 percent

2022

15 percent

2023

15 percent

2024

15 percent

2025

15 percent

2026

15 percent

The principal author of this notice

is Alan W. Tilley of the Office of Associate Chief Counsel (Energy, Credits,

Bulletin No. 2026–25

and Excise Tax). For further information

regarding this notice, contact Mr. Tilley

1581

at (317) 512-6512 (not a toll-free number).

June 15, 2026

26 CFR 601.602: Tax forms and instructions.

(Also: Part I, §§ 1, 223, Part III § 54.9831-1)

Rev. Proc.2026-24

SECTION 1. PURPOSE

This revenue procedure provides

the 2027 inflation adjusted amounts for

Health Savings Accounts (HSAs) as determined under section 223 of the Internal

Revenue Code (Code) and the maximum

amount that may be made newly available

for excepted benefit health reimbursement

arrangements (HRAs) provided under

§ 54.9831-1(c)(3)(viii) of the Pension

Excise Tax Regulations.

SECTION 2. LEGISLATIVE

CHANGES

.01 Section 71308 of Public Law 11921, 139 Stat. 72, 325-326 (July 4, 2025),

commonly known as the One, Big, Beautiful Bill Act, added section 223(c)(1)(E)

to the Code. Under section 223(c)(1)(E),

a direct primary care service arrangement

(DPCSA) shall not be treated as a health

plan for the purposes of section 223(c)

(1)(A)(ii) provided that, with respect to

any individual for any month, the aggregate fees for all DPCSAs with respect to

the individual do not exceed $150 ($300

in the case of an individual with any

DPCSA that covers more than one individual). Section 223(c)(1)(E) is effective

June 15, 2026

for months beginning after December 31,

2025. The $150 and $300 amounts are

adjusted for inflation for months beginning after December 31, 2026.

SECTION 3. 2027 INFLATION

ADJUSTED ITEMS

.01 HSA Inflation Adjusted Items.

(1) Annual contribution limitation. For

calendar year 2027, the annual limitation

on deductions under section 223(b)(2)

(A) for an individual with self-only coverage under a high deductible health plan

is $4,500. For calendar year 2027, the

annual limitation on deductions under section 223(b)(2)(B) for an individual with

family coverage under a high deductible

health plan is $9,000.

(2) Maximum monthly aggregate fees

for all DPCSAs. For calendar year 2027, a

DPCSA is not treated as a health plan with

respect to an otherwise eligible individual

if the aggregate monthly fees for all DPCSAs with respect to the individual do not

exceed $150 or, if the individual is covered by a DPCSA that covers more than

one individual, $300.

(3) High deductible health plan. For

calendar year 2027, a “high deductible

health plan” is defined under section

223(c)(2)(A) as a health plan with an

annual deductible that is not less than

$1,750 for self-only coverage or $3,500

for family coverage, and for which the

annual out-of-pocket expenses (deductibles, co-payments, and other amounts,

1582

but not premiums) do not exceed $8,700

for self-only coverage or $17,400 for family coverage.

.02 HRA Inflation Adjusted Item.

For plan years beginning in 2027,

the maximum amount that may be made

newly available for the plan year for an

excepted benefit HRA under § 54.98311(c)(3)(viii) is $2,250. See § 54.9831-1(c)

(3)(viii)(B)(1) for further explanation of

this calculation.

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective for

HSAs for calendar year 2027, for DPCSAs for months beginning in calendar

year 2027, and for excepted benefit HRAs

for plan years beginning in 2027.

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Michael Finn of the Office

of Associate Chief Counsel (Income Tax

& Accounting). For further information

regarding the calculations in this revenue

procedure contact Mr. Finn at (202) 3174718 (not a toll-free number). For further

information regarding section 223, HSAs,

DPCSAs and excepted benefit HRAs,

contact the Health and Welfare Branch

in the Office of Associate Chief Counsel

(Employee Benefits, Exempt Organizations, and Employment Taxes) at (202)

317-5500 (not a toll-free number).

Bulletin No. 2026–25

Part IV

Notice of Proposed

Rulemaking

Income of Foreign

Governments and of

International Organizations

CC-00349656-26

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Notice of proposed rulemaking; partial withdrawal of proposed

rulemaking.

SUMMARY: This document contains

proposed regulations regarding the applicability dates of proposed rules relating to

the taxation of the income of foreign governments from investment in the United

States. This document also withdraws a

portion of the proposed regulations published on December 15, 2025, relating to

applicability dates.

DATES: Written or electronic comments

and requests for a public hearing must be

received by July 31, 2026. As of June 1,

2026, proposed §§ 1.892-4(d) and 1.8925(e), contained in the notice of proposed

rulemaking published in the Federal

Register on December 15, 2025 (90 FR

57928), are withdrawn.

ADDRESSES: Commenters are strongly

encouraged to submit public comments

electronically via the Federal eRulemaking Portal at https://www.regulations.

gov (indicate IRS and CC-0034965626) by following the online instructions

for submitting comments. Requests for a

public hearing must be submitted as prescribed in the “Comments and Requests

for a 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

Bulletin No. 2026–25

public docket. Send paper submissions

to: CC:PA:01:PR (CC-00349656-26),

Room 5503, Internal Revenue Service,

P.O. Box 7604, Ben Franklin Station,

Washington, DC 20044.

FOR FURTHER INFORMATION

CONTACT: Concerning the proposed

regulations, Jack Zhou at (202) 317-6938;

concerning submissions of comments,

requests for a public hearing, and access

to a public hearing, Publication and Regulations Section at (202) 317-6901 (not

toll-free numbers) or by email to publichearings@irs.gov (preferred).

SUPPLEMENTARY INFORMATION:

Authority

This document contains proposed

amendments to the Income Tax Regulations (26 CFR part 1) under section 892 of

the Internal Revenue Code (Code). These

proposed regulations are issued under the

express delegations of authority under

sections 892(c) and 7805(a) of the Code.

Background

I. 2025 Proposed Regulations under

Section 892

On December 15, 2025, the Treasury Department and the IRS published

in the Federal Register (90 FR 57928)

proposed regulations (the 2025 proposed

regulations) under section 892 relating

to taxation of the income of foreign governments from investments in the United

States. The 2025 proposed regulations

would provide guidance for determining

whether an acquisition of debt is commercial activity, and whether a foreign

government has effective control of an

entity. See proposed §§ 1.892-4(c)(1)(ii)

and 1.892-5(c)(2). The 2025 proposed

regulations are proposed to apply to taxable years beginning on or after the date

of publication of the Treasury decision

adopting the 2025 proposed regulations

as final regulations (the final regulations). See proposed §§ 1.892-4(d) and

1.892-5(e).

1583

II. Comments on the Proposed

Applicability Dates

Following the publication of the

2025 proposed regulations, the Treasury

Department and the IRS received comments requesting transitional relief with

respect to the proposed applicability dates.

Commenters requested that the proposed

debt acquisition rules, when finalized,

apply only to debt instruments acquired

on or after the publication date of the final

regulations (the publication date). Commenters also requested a rule that would

preserve the application of existing rules

under section 892 to debt acquired before

the publication date and to debt acquired

on or after the publication date pursuant

to a legally binding commitment entered

into before the publication date. Alternatively, a commenter requested an extended

period of time after the publication date

during which foreign governments could

continue relying on the existing rules for

outstanding debt instruments and commitments while they reposition their interests

to accord with the final regulations. In

addition, a commenter requested a transition rule that would preserve the application of existing rules for debt instruments

acquired on or before 90 days after the

publication date of the final regulations

and for debt instruments acquired after

that date but pursuant to a binding commitment entered into on or before that

date.

Likewise, commenters requested that

the proposed effective control rules, when

finalized, apply only to rights granted (or

materially expanded) on or after the publication date. Commenters recommended a

rule that would preserve the application of

existing rules under section 892 to arrangements in place before the publication date

as well as to entity interests acquired pursuant to legally binding commitments

entered into before the publication date.

Alternatively, commenters requested an

extended period after the publication date

during which foreign governments may

continue relying on the existing rules

with respect to existing interests, and not

have to consider renegotiating or restructuring certain legacy holdings solely due

June 15, 2026

to the final regulations. Similarly, one

commenter requested a transition rule

that would preserve the application of the

existing rules for agreements and other

arrangements entered into on or before 90

days after the publication date.

Explanation of Provisions

I. New Proposed Applicability Dates

As a general matter, the Treasury

Department and the IRS did not intend

for the 2025 proposed regulations, once

finalized, to apply retroactively to existing

foreign government holdings of debt and

of interests in entities (collectively, foreign government holdings). In addition, in

response to the comments, these proposed

regulations would include additional transitional relief. Accordingly, this notice

of proposed rulemaking withdraws the

applicability dates in §§ 1.892-4(d) and

1.892-5(e) of the 2025 proposed regulations and proposes new applicability dates

to ensure that certain existing foreign

government holdings, as well as holdings

acquired during a transition period, would

not be subject to the final regulations. The

existing rules under section 892 would

continue to apply to foreign government

holdings acquired before the applicability

date and to foreign government holdings

acquired on or after the applicability date

if acquired pursuant to a binding commitment entered into before the applicability

date.

These proposed regulations would

address only the proposed applicability

dates of the 2025 proposed regulations.

The Treasury Department and the IRS

recognize the importance of the issues

raised by stakeholders on the substantive aspects of the 2025 proposed regulations. The Treasury Department and

the IRS have received 18 comments on

the 2025 proposed regulations—including with respect to the debt acquisition

rules and the effective control rules—

and are evaluating how to reflect these

comments in the next phase of this project by taking into account established

market practices and the general policy

to support current and future sovereign

wealth fund investment in the United

States. Any terms used but not defined

in this preamble have the meanings

June 15, 2026

given to them in the 2025 proposed regulations.

II. Applicability Date for Debt

Acquisition Rules

Proposed § 1.892-4(d)(2) would provide foreign governments with a transition

period of at least 90 days after the publication date, or until the start of the first taxable year after the publication date, before

the debt acquisition rules in the final regulations apply.

Under proposed § 1.892-4(d)(4), if debt

is acquired before the end of the transition

period or is acquired pursuant to a binding

commitment entered into before the end

of the transition period, the existing rules

applicable before the final regulations

are published would continue to apply

to determine whether that acquisition is

commercial activity, and, accordingly,

whether income received from that debt in

future periods is derived from commercial

activity.

Because it is the acquisition of debt,

and not the mere holding of debt, that is

potentially treated as commercial activity for purposes of section 892, a debt

acquirer is not engaged in commercial

activity in taxable years following the

taxable year of the acquisition of the debt

solely by reason of holding the debt in

the subsequent taxable years. Furthermore, a debt that was acquired in a previous year and held in the current year does

not cause other debt acquisitions in the

current year to be treated as commercial

activity.

III. Applicability Date for Effective

Control Rules

Proposed § 1.892-5(e)(2)(i) would similarly provide foreign governments with a

transition period of at least 90 days after

the publication date, or until the start of

the first taxable year after the publication

date, before the effective control rules in

the final regulations apply.

Under proposed § 1.892-5(e)(2)(ii), the

effective control rules in the final regulations would not apply to a foreign government’s existing interests in an entity unless

the foreign government acquires, after the

transition period, and excluding acquisitions pursuant to a binding commitment

1584

entered into before the end of the transition period, new interests in the entity that,

by themselves, would provide the foreign

government with effective control under

the final regulations. Unless and until this

occurs, whether that entity is a controlled

commercial entity would be determined

under the existing rules applicable before

the final regulations are published, which

will take into account all interests, regardless of when acquired.

Special Analyses

I. Regulatory Planning and Review –

Economic Analysis

These proposed regulations are not

subject to review under section 6(b) of

Executive Order 12866 pursuant to the

Memorandum of Agreement (July 4,

2025) between the Treasury Department

and the Office of Management and Budget (OMB) regarding review of tax regulations.

II. Paperwork Reduction Act

The Paperwork Reduction Act of 1995

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

that a Federal agency obtain the approval

of the OMB before collecting information

from the public, whether such collection

of information is mandatory, voluntary,

or required to obtain or retain a benefit.

There are no additional information collection requirements associated with these

proposed regulations.

III. Regulatory Flexibility Act

Pursuant to the Regulatory Flexibility

Act (5 U.S.C. chapter 6), it is hereby certified that this rulemaking will not have a

significant economic impact on a substantial number of small entities within the

meaning of section 601(6) of the Regulatory Flexibility Act. This certification is

based on the fact that the proposed regulations affect foreign governments, including their controlled entities, with income

from sources within the United States.

Accordingly, the entities affected by the

proposed regulations are not considered

small entities, and a regulatory flexibility

analysis under the Regulatory Flexibility

Act is not required.

Bulletin No. 2026–25

IV. Section 7805(f)

Pursuant to section 7805(f) of the

Code, these proposed regulations will be

submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small

business.

V. Unfunded Mandates Reform Act

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. The

proposed 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.

VI. Executive Order 13132: Federalism

Executive Order 13132 (entitled

“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. The 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.

Comments and Requests for Public

Hearing

Before the proposed regulations are

adopted as final regulations, consideration

will be given to any comments that are

submitted timely to the IRS as prescribed

in the preamble under the ADDRESSES

heading. The Treasury Department and

the IRS request comments on all aspects

of the proposed regulations. Any comments submitted will be made available

Bulletin No. 2026–25

at https://www.regulations.gov or upon

request.

A public hearing will be scheduled if

requested in writing by any person who

submits electronic or written comments.

Requests for a public hearing are also

encouraged to be made electronically. If

a public hearing is scheduled, notice of

the date and time for the public hearing

will be published in the Federal Register.

Drafting Information

The principal authors of the proposed

regulations are Jack Zhou and Peter

Merkel of the Office of Associate Chief

Counsel (International). However, other

personnel from the Treasury Department

and the IRS participated in their development.

Partial Withdrawal of Proposed

Regulations

Under the authority of 26 U.S.C.

892(c) and 7805, proposed §§ 1.8924(d) and 1.892-5(e), contained in the

notice of proposed rulemaking that was

published in the Federal Register on

December 15, 2025 (90 FR 57928), are

withdrawn.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the

Regulations

Accordingly, the Treasury Department

and the IRS propose to amend 26 CFR

part 1 as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as follows:

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

Par. 2. Section 1.892-4 is amended

by:

a. Redesignating paragraph (d) as paragraph (d)(1);

b. Revising the heading of newly redesignated paragraph (d)(1); and

1585

c. Adding paragraphs (d)(2) introductory text and (d)(3) and (4).

The revision and additions read as follows:

§ 1.892-4 Commercial activities.

*****

(d) Applicability date—(1) In general.

***

(2) Debt acquisition applicability date.

Except as provided in paragraph (d)(3) of

this section, paragraph (c)(1) of this section applies to acquisitions of debt on or

after the date that is the later of:

(i) The first day of the acquirer’s first

taxable year beginning on or after [DATE

OF PUBLICATION OF FINAL RULE],

or

(ii) 90 days after [DATE OF PUBLICATION OF FINAL RULE].

(3) Binding commitment rule. Paragraph (c)(1) of this section does not apply

to debt acquired pursuant to a binding

commitment entered into before the later

of the dates described in paragraphs (d)(2)

(i) and (ii) of this section.

(4) Rules for debt acquisitions and

commitments before the applicability

date. Debt acquired before the later of the

dates described in paragraphs (d)(2)(i) and

(ii) of this section or pursuant to a binding commitment described in paragraph

(d)(3) of this section shall continue to be

governed by §§ 1.892-4 and 1.892-4T, as

contained in 26 CFR in part 1 in effect on

April 1, 2026.

Par. 3. Section 1.892-5 is amended by:

a. Redesignating paragraph (e) as paragraph (e)(1);

b. Revising the heading of newly redesignated paragraph (e)(1); and

c. Adding paragraph (e)(2) introductory text.

The revision and addition read as follows:

§ 1.892-5 Controlled commercial entity.

*****

(e) Applicability date—(1) In general.

***

(2) Effective control applicability

date—(i) In general. Except as provided

in paragraph (e)(2)(ii) of this section,

paragraph (c)(2) of this section applies to

determine whether a foreign government

June 15, 2026

has effective control of an entity on or

after the date that is the later of:

(A) The first day of the foreign government’s first taxable year beginning on

or after [DATE OF PUBLICATION OF

FINAL RULE], or

(B) 90 days after [DATE OF PUBLICATION OF FINAL RULE].

(ii) Rules with respect to previously

acquired interests. If a foreign government holds any previously acquired interests (as defined in paragraph (e)(2)(ii)(B)

of this section) in an entity, paragraph (c)

(2) of this section applies to determine

whether the foreign government has

effective control of the entity beginning

on the date on which the foreign gov-

June 15, 2026

ernment first acquires new controlling

interests (as defined in paragraph (e)(2)

(ii)(A) of this section) in the entity. Until

the date that the foreign government first

acquires new controlling interests in the

entity, all of the foreign government’s

interests in that entity shall continue to

be governed by §§ 1.892-5 and 1.892-5T,

as contained in 26 CFR in part 1 in effect

on April 1, 2026.

(A) New controlling interests. For purposes of this paragraph (e)(2)(ii), the term

new controlling interests means one or

more interests in an entity, other than any

previously acquired interests (as defined

in paragraph (e)(2)(ii)(B) of this section),

that in the aggregate result in effective

1586

control of the entity under paragraph (c)

(2) of this section.

(B) Previously acquired interests. For

purposes of this paragraph (e)(2)(ii), the

term previously acquired interests means

one or more interests in an entity acquired

by a foreign government before the later

of the dates described in paragraphs (e)(2)

(i)(A) and (B) of this section, or acquired

pursuant to a binding commitment entered

into before the later of such dates.

Frank J. Bisignano,

Chief Executive Officer.

(Filed by the Office of the Federal Register May 29,

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

Federal Register for June 01, 2026, 91 FR 32366)

Bulletin No. 2026–25

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. 2026–25

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 15, 2026

Numerical Finding List1

Proposed Regulations:—Continued

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

AOD:

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

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

Revenue Procedures:

Notices:

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

Bulletin 2026–25

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

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

Proposed Regulations:

Revenue Rulings:

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

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

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

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

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

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

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

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

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

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

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

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

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

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 15, 2026

ii

Bulletin No. 2026–25

Finding List of Current Actions on

Previously Published Items1

Bulletin 2026–25

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. 2026–25

iii

June 15, 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.