Bulletin No. 2026–15
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HIGHLIGHTS
OF THIS ISSUE
Bulletin No. 2026–15
April 6, 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, SPECIAL
ANNOUNCEMENT
ing under section 42(h) of the Code, (2) private activity bond
volume cap under section 146, and (3) private activity bond
volume limit under section 142(k) are reproduced.
Notice 2026-23, page 804.
Rev. Proc. 2026-17, page 805.
This notice requests recommendations from the public for
guidance items that should be included on the 2026-2027
Priority Guidance Plan.
EMPLOYEE PLANS
Notice 2026-19, page 797.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for February 2026 used under § 417(e)(3)(D), the 24-month average
segment rates applicable for March 2026, and the 30-year
Treasury rates, as reflected by the application of § 430(h)(2)
(C)(iv).
INCOME TAX
Notice 2026-20, page 800.
This notice extends the temporary relief provided in section 4.02 of Notice 2025-7, 2025-5 I.R.B. 524 (January
27, 2025), for an additional year. Specifically, this notice
allows eligible taxpayers to use certain alternative methods
for making an adequate identification, within the meaning of
§ 1.1012-1(j)(3)(ii), with respect to units of a digital asset
held in the custody of a broker that are sold, disposed of, or
transferred during the relief period specified in this notice.
Notice 2026-22, page 802.
Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas for purposes of determining the 2026 calendar year (1) state housing credit ceil-
Finding Lists begin on page ii.
This revenue procedure provides guidance on the withdrawal
of elections to be excepted trades or businesses under
§ 163(j)(7) for purposes of the business interest limitation
and to make a late election under § 168(k)(7) to be exempt
from bonus depreciation. This revenue procedure also provides guidance on the early election or revocation of a CFC
group election under 1.163(j)-7(e). Taxpayers in identified
fields are permitted to withdraw an election previously made
under § 163(j) and make the associated depreciation adjustments under § 168(k) or make a late election out of applying
bonus depreciation under § 168(k). Separately, a CFC group
may either make or revoke their specific group election
regardless of whether the requisite 60-month requirement of
§ 1.163(j)-7(e)(5)(ii) is satisfied.
Rev. Rul. 2026-7, page 791.
Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for April 2026.
T.D.10043, page 793.
These final regulations relate to the definition of qualified nonpersonal use vehicles. Qualified nonpersonal use vehicles are
excepted from the substantiation requirements that apply to
certain listed property. These final regulations add unmarked
vehicles used by firefighters or members of a rescue squad
or ambulance crew as a new type of qualified nonpersonal
use vehicle. These final regulations affect governmental units
that provide firefighter or rescue squad or ambulance crew
member employees with unmarked qualified nonpersonal
use vehicles and the employees who use those vehicles.
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.
April 6, 2026
Bulletin No. 2026–15
Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7702, 7872.)
Rev. Rul. 2026-7
This revenue ruling provides various
prescribed rates for federal income tax
Annual
AFR
110% AFR
120% AFR
130% AFR
3.59%
3.96%
4.32%
4.68%
AFR
110% AFR
120% AFR
130% AFR
150% AFR
175% AFR
3.82%
4.20%
4.59%
4.97%
5.75%
6.73%
AFR
110% AFR
120% AFR
130% AFR
4.62%
5.09%
5.56%
6.03%
Short-term adjusted AFR
Mid-term adjusted AFR
Long-term adjusted AFR
Bulletin No. 2026–15
purposes for April 2026 (the current
month). Table 1 contains the shortterm, mid-term, and long-term applicable federal rates (AFR) for the current
month for purposes of section 1274(d)
of the Internal Revenue Code. Table 2
contains the short-term, mid-term, and
long-term adjusted applicable federal
rates (adjusted AFR) for the current
month for purposes of section 1288(b).
Table 3 sets forth the adjusted federal long-term rate and the long-term
tax-exempt rate described in section
382(f). Table 4 contains the appropri-
ate percentages for determining the
low-income housing credit described in
section 42(b)(1) for buildings placed in
service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service
after July 30, 2008, shall not be less
than 9%. Finally, Table 5 contains the
federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.
REV. RUL. 2026-7 TABLE 1
Applicable Federal Rates (AFR) for April 2026
Period for Compounding
Semiannual
Quarterly
Short-term
3.56%
3.54%
3.92%
3.90%
4.27%
4.25%
4.63%
4.60%
Mid-term
3.78%
3.76%
4.16%
4.14%
4.54%
4.51%
4.91%
4.88%
5.67%
5.63%
6.62%
6.57%
Long-term
4.57%
4.54%
5.03%
5.00%
5.48%
5.44%
5.94%
5.90%
Annual
2.72%
2.89%
3.50%
REV. RUL. 2026-7 TABLE 2
Adjusted AFR for April 2026
Period for Compounding
Semiannual
2.70%
2.87%
3.47%
791
Quarterly
2.69%
2.86%
3.46%
Monthly
3.53%
3.89%
4.23%
4.59%
3.75%
4.12%
4.50%
4.86%
5.60%
6.53%
4.53%
4.98%
5.42%
5.87%
Monthly
2.68%
2.85%
3.45%
April 6, 2026
REV. RUL. 2026-7 TABLE 3
Rates Under Section 382 for April 2026
Adjusted federal long-term rate for the current month
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)
3.50%
3.58%
REV. RUL. 2026-7 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for April 2026
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit
7.98%
Appropriate percentage for the 30% present value low-income housing credit
3.42%
REV. RUL. 2026-7 TABLE 5
Rate Under Section 7520 for April 2026
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of April 2026. See Rev.
Rul. 2026-7, page 791.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of April 2026. See Rev. Rul.
2026-7, page 791.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
4.6%
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month
of April 2026. See Rev. Rul. 2026-7, page 791.
Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of April 2026. See Rev. Rul.
2026-7, page 791.
Section 7872.—Treatment
of Loans With BelowMarket Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2026. See Rev. Rul. 2026-7, page 791.
April 6, 2026
792
Bulletin No. 2026–15
26 CFR 1.132-0 through 1.132-8T and 1.274-5
T.D. 10043
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Substantiation
Requirements and Qualified
Nonpersonal Use Vehicles
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulation.
SUMMARY: This document contains
final regulations relating to the definition
of qualified nonpersonal use vehicles.
Qualified nonpersonal use vehicles are
excepted from the substantiation requirements that apply to certain listed property.
These final regulations add unmarked
vehicles used by firefighters or members
of a rescue squad or ambulance crew as
a new type of qualified nonpersonal use
vehicle. These final regulations affect governmental units that provide firefighter or
rescue squad or ambulance crew member
employees with unmarked qualified nonpersonal use vehicles and the employees
who use those vehicles.
DATES: Effective date: These final regulations are effective on March 20, 2026.
Applicability date: §1.274-5(k)(2)(ii)
(S), (k)(7), (k)(9)(v) and references to
§1.274-5(k)(9) in §1.132-5(h) apply to
taxable years ending on or after March 20,
2026.
FOR FURTHER INFORMATION
CONTACT: Stephanie Caden at (202)
317-4774 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Authority
These final regulations are issued under
the authority granted to the Secretary of
the Treasury or his delegate (Secretary)
Bulletin No. 2026–15
by sections 274(p), 132(o), and 7805(a) of
the Internal Revenue Code (Code). Section 274(p) provides the Secretary with
an express grant of authority to prescribe
such regulations as the Secretary may
deem necessary to carry out the purposes
of that section. Section 132(o) provides
the Secretary with an express grant of
authority to prescribe such regulations as
may be necessary or appropriate to carry
out the purposes of that section. Section
7805(a) authorizes the Secretary to prescribe all needful rules and regulations for
the enforcement of the Code.
Background
This document contains amendments
to the Income Tax Regulations (26 CFR
part 1) under sections 132 and 274. In
general, section 274 limits or disallows
deductions for certain expenditures that
otherwise would be allowable under chapter 1 of the Code, primarily under section 162(a), which allows a deduction for
ordinary and necessary expenses paid or
incurred during the taxable year in carrying on any trade or business.
Section 274(d), as relevant to these final
regulations, provides that a taxpayer is not
allowed a deduction or credit for certain
expenses unless the expenses are substantiated by adequate records or by sufficient
evidence corroborating the taxpayer’s
own statement as to the amount, time and
place, and business purposes of the expenditure, and the business relationship to
the taxpayer of the person receiving the
benefit. These substantiation requirements
apply to expenses incurred in the use of
any listed property, as defined in section
280F(d)(4), which includes any passenger
automobile and any other property used
as a means of transportation. However,
section 274(d) also provides that qualified
nonpersonal use vehicles are excepted
from these substantiation requirements.
Section 274(i) defines a qualified nonpersonal use vehicle as one which, by
reason of its nature, “is not likely to be
used more than a de minimis amount for
personal purposes.” Current regulations
under section 274 define qualified nonpersonal use vehicles to include clearly
marked police, fire, or public safety officer vehicles that are owned or leased by a
governmental unit and required to be used
793
for commuting by a police officer, firefighter, or public safety officer (as defined
in section 402(l)(4)(C)) who, when not
on a regular shift, is on call at all times.
Any personal use (other than commuting) of the vehicle outside the limit of
the police officer’s arrest powers or the
firefighter’s or public safety officer’s obligation to respond to an emergency must
be prohibited by the governmental unit.
See §1.274-5(k)(2)(ii)(A) and (k)(3). The
various examples included in §1.274-5(k)
(8) illustrate that a prohibition on personal
use (other than commuting) is intended to
exist in situations where both commuting
and only de minimis personal use, such as
personal errands, are permitted.
The current regulations also define
qualified nonpersonal use vehicles as
including unmarked law enforcement
vehicles owned or leased by Federal, State,
county, or local governmental agencies or
departments that officially authorize the
business and personal use of the vehicle
by law enforcement officers whom they
employ, provided any personal use is incidental to law enforcement functions. See
§1.274-5(k)(2)(ii)(R) and (k)(6). The current regulations define law enforcement
officers as individuals who are employed
on a full-time basis by a governmental
unit that is responsible for the prevention or investigation of crime involving
injury to persons or property (including
apprehension or detention of persons for
those crimes), who are authorized by law
to carry firearms, execute search warrants,
and to make arrests (other than merely a
citizen’s arrest), and who regularly carry
firearms (except when it is not possible
to do so because of the requirements of
undercover work). See §1.274-5(k)(6)
(ii). Unmarked law enforcement vehicles
allow law enforcement officers to operate inconspicuously, e.g., so that they can
conduct these duties while performing
undercover work.
The current regulations do not include
unmarked vehicles used by firefighters,
members of rescue squads, or ambulance
crews in the definition of qualified nonpersonal use vehicles. Historically, firefighters and rescue squad and ambulance
crew members were provided with vehicles that had markings to indicate their
status as emergency response vehicles.
More recently, however, the IRS and Trea-
April 6, 2026
sury Department have become aware that
some governmental units are assigning
these emergency responders unmarked
vehicles due to increased incidents of
harassment of first responders and vandalism of clearly marked fire and emergency
vehicles and equipment.
The use of unmarked vehicles allows
firefighters and other emergency personnel who commute and are required to be
on call at all times, even when not on a
regular shift, to travel inconspicuously,
thereby reducing risk of harassment and
vandalism. Also, unmarked firefighter and
rescue squad or ambulance crew vehicles typically are specially outfitted with
onboard equipment, which is used by
firefighters and emergency personnel to
suppress fires, conduct rescue activities,
or provide emergency medical services as
part of an official emergency response system. Because these vehicles are generally
specially outfitted with such equipment,
any personal use of these vehicles is likely
to be minimal. Thus, adding unmarked
firefighter, rescue squad or ambulance
crew vehicles as a new category of qualified nonpersonal use vehicle in the regulations is consistent with the underlying
intent of section 274(i).
On December 3, 2024, a notice of
proposed rulemaking (NPRM) (REG106595-22) was published in the Federal Register (89 FR 95727) that proposed amending §1.274-5(k)(2)(ii) to
add unmarked vehicles used by firefighters, members of rescue squads, or
ambulance crews to the list of qualified
nonpersonal use vehicles that are exempt
from the substantiation requirements
of section 274(d). The NPRM also proposed amending §1.274-5(k) to add a
new §1.274-5(k)(7) providing definitions
for the terms “unmarked firefighter, rescue squad or ambulance crew vehicles”,
“firefighter,” and “member of a rescue
squad or ambulance crew,” and proposed
adding §1.274-5(k)(9)(v) (Example 5)
illustrating the new provision. Finally,
the NPRM proposed making conforming
amendments to §§1.132-1(g) and 1.1325(h)(1).
No public hearing was requested or
held. Three comments responding to the
NRPM were received. All comments
were considered and are available for
public inspection and copying at http://
April 6, 2026
www.regulations.gov or upon request.
The public comments are discussed in
the Summary of Comments section of
this preamble.
Special Analyses
Summary of Comments
These final regulations are not subject
to review under section 6(b) of Executive
Order 12866 pursuant to the Memorandum of Agreement (July 4, 2025) between
the Treasury Department and the Office
of Management and Budget regarding
review of tax regulations.
One commenter provided comments
on issues that are unrelated to the Code or
tax administration in general and therefore
are outside the scope of these regulations.
Another commenter expressed appreciation that firefighters and members of
rescue squads and ambulance crews were
being granted the same tax treatment as
other first responders who use qualified
nonpersonal use vehicles. The commenter
noted the need for fire department personnel who maintain 24-hour response
capacity to use unmarked vehicles to
travel inconspicuously for security purposes and reduce the risk of harassment
and vehicle damage. The commenter further noted that including unmarked nonpersonal use vehicles used by firefighters,
members of rescue squads, or ambulance
crews on the list of qualified nonpersonal use vehicles will ensure that those
who respond to emergencies in specially
equipped unmarked vehicles will be able
to continue to do so without unreasonable
financial burden.
Another commenter asked what the
proposed rule would cost in terms of lost
tax revenue. These regulations will not
have a significant economic impact and
are not subject to review under section
6(b) of Executive Order 12866. Accordingly, the Treasury Department and the
IRS have not conducted an analysis of the
revenue impact of the rule.
The Treasury Department and the
IRS requested comments on whether the
definitions of “unmarked firefighter, rescue squad or ambulance crew vehicles,”
“firefighter,” and “member of a rescue
squad or ambulance crew,” are sufficient
to accomplish the intended purpose of
the proposed regulations or whether any
of them might lead to potential abuse. No
comments were received regarding these
definitions.
After consideration of the comments,
these final regulations adopt all the provisions of the proposed regulations with
some minor, non-substantive changes to
certain provisions.
794
I. Regulatory Planning and Review—
Economic Analysis
II. Paperwork Reduction Act
These final regulations do not create
new collection requirements, as defined
under the Paperwork Reduction Act (44
U.S.C. 35); and do not alter any previously
approved Office of Management and Budget information collection requirements
and their associated burden.
III. Regulatory Flexibility Act
It is hereby certified that these final
regulations will not have a significant
economic impact on a substantial number of small entities pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter
6). This certification is based on the fact
that these final regulations do not impose
any new or different requirements on
small entities. These final regulations
would apply only to employers that utilize unmarked firefighter, rescue squad,
or ambulance vehicles and therefore
would affect a relatively small number
of entities. In addition, these final regulations would not affect employment tax
reporting or require any additional substantiation. Rather, these final regulations
exempt affected entities from substantiation requirements and for this reason do
not add any economic burden to affected
entities. Therefore, a Regulatory Flexibility Analysis under the Regulatory
Flexibility Act (5 U.S.C. chapter 6) is not
required. The Treasury Department and
the IRS did not receive any comments on
any impact these final regulations would
have on small entities.
IV. Section 7805(f)
Pursuant to section 7805(f) of the Internal Revenue Code, the NPRM preceding
Bulletin No. 2026–15
this regulation was submitted to the Chief
Counsel for Advocacy of the Small Business Administration for comment on its
impact on small business. No comment
was received.
Adoption of Amendments to the
Regulations
V. Unfunded Mandates Reform Act
PART 1--INCOME TAXES
Section 202 of the Unfunded Mandates Reform Act of 1995 requires that
agencies assess anticipated costs and
benefits and take certain other actions
before issuing a final rule that includes
any Federal mandate that may result
in expenditures in any one year by a
State, local, or Tribal government, in
the aggregate, or by the private sector,
of $100 million in 1995 dollars, updated
annually for inflation. These final regulations do not include any Federal mandate that may result in expenditures by
State, local, or Tribal governments, or
by the private sector, in excess of that
threshold.
Paragraph 1. The authority citation
for part 1 is amended by revising the
entries for §§1.132-0 through 1.132-8T
and §1.274-5 to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
*****
Sections 1.132-0 through 1.132-8T also
issued under 26 U.S.C. 132(o).
*****
Section 1.274-5 also issued under 26
U.S.C. 274(p).
*****
Par. 2. Section 1.132-1 is amended by
adding a sentence to the end of paragraph
(g) to read as follows:
VI. Executive Order 13132: Federalism
Executive Order 13132 (Federalism)
prohibits an agency from publishing any
rule that has federalism implications if
the rule either imposes substantial, direct
compliance costs on State and local governments, and is not required by statute,
or preempts State law, unless the agency
meets the consultation and funding
requirements of section 6 of the Executive
order. These final regulations do not have
federalism implications, do not impose
substantial direct compliance costs on
State and local governments, and do not
preempt State law within the meaning of
the Executive order.
Drafting Information
The principal author of these final regulations is Stephanie L. Caden of the Office
of the Associate Chief Counsel (Employee
Benefits, Exempt Organizations, and
Employment Taxes). However, other personnel from the Treasury Department and
the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Bulletin No. 2026–15
Accordingly, 26 CFR part 1 is amended
as follows:
§1.132-1 Exclusion from gross income
for certain fringe benefits.
*****
(g) * * * In addition, references to
§1.274-5(k)(9) in §1.132-5(h) are applicable as of March 20, 2026.
§1.132-5 [Amended]
Par. 3. Section 1.132-5 is amended
by, in paragraph (h)(1), removing the text
“§1.274-5(k)(3) through (8)” and adding
the text “§1.274-5(k)(3) through (9)” in
its place, and removing the text “paragraphs (k)(3) through (8)” and adding
the text “§1.274-5(k)(3) through (9)” in
its place.
Par. 4. Section 1.274-5 is amended
by:
1. Redesignating paragraph (k)(2)(ii)
(S) as paragraph (k)(2)(ii)(T) and adding
new paragraph (k)(2)(ii)(S);
2. Redesignating paragraphs (k)(7) and
(8) as paragraphs (k)(8) and (9) and adding a new paragraph (k)(7);
3. In newly redesignated paragraph (k)
(9), designating Examples 1 through 4 as
paragraphs (k)(9)(i) through (k)(9)(iv),
respectively.
4. Adding paragraph (k)(9)(v); and
5. Revising paragraph (m).
The additions read as follows:
795
§1.274-5 Substantiation requirements.
*****
(k) * * *
(2) * * *
(ii) * * *
(S) Unmarked firefighter, rescue squad,
or ambulance crew vehicles (as defined in
paragraph (k)(7) of this section).
*****
(7) Unmarked firefighter, rescue squad,
or ambulance crew vehicles--(i) In general. The substantiation requirements
of section 274(d) and this section do not
apply to an unmarked firefighter, rescue squad, or ambulance crew vehicle
required to be used for commuting by the
firefighter or member of a rescue squad
or ambulance crew, who, when not on a
regular shift, is on call at all times. Personal use (other than commuting) of the
vehicle outside the firefighter’s or rescue
squad or ambulance crew member’s obligation to respond to an emergency must
be prohibited by the governmental unit, or
any agency or instrumentality thereof, that
owns or leases the vehicle and employs
the firefighter, member of a rescue squad,
or ambulance crew member.
(ii) Unmarked firefighter, rescue squad,
or ambulance crew vehicle defined. An
unmarked firefighter, rescue squad, or
ambulance crew vehicle is an unmarked
vehicle used by a firefighter, or member of
a rescue squad or ambulance crew, that is
owned or leased by a governmental unit,
or any agency or instrumentality thereof,
and that is specially outfitted to allow
firefighters or members of rescue squads
and ambulance crews to travel safely and
efficiently to the scene of an emergency
and provide emergency services. Onboard
equipment on the vehicles includes but is
not limited to lights and sirens, medical
emergency equipment, life-saving devices
such as defibrillators, and radios that assist
firefighters, rescue squads, or ambulance
crews in communicating with a central
source or other emergency response crews
regarding, for example, traffic or hospital
capacity. Onboard equipment may also
include items such as personal protective equipment (e.g., helmet, coat, boots),
emergency oxygen tanks, reference manuals, and laptop computers that enable
workers to access important information
related to the emergency. A license plate
April 6, 2026
marking or insignia does not disqualify
a vehicle from being an unmarked firefighter, rescue squad, or ambulance crew
vehicle for purposes of this paragraph (k)
(7).
(iii) Firefighter. The term firefighter
means an individual who is employed
by a governmental unit, or any agency or
instrumentality thereof, that is responsible for firefighting, rescue activity, or the
provision of emergency medical care, and
other related emergency services to prevent injury to persons or property and has
the official authority to engage in fire suppression and provide related emergency
services.
(iv) Member of a rescue squad or ambulance crew. For purposes of this paragraph
(k)(7), the term member of a rescue squad
or ambulance crew has the same meaning
as in 34 U.S.C. 10284(10)(A).
*****
April 6, 2026
(9) * * *
(v) Example 5. Emergency medical technician,
X, is a member of a rescue squad employed by
City M. X is provided with an unmarked vehicle
(equipped with sirens and medical equipment) for
use in responding to emergencies. X, along with
other members of the rescue squad, is ordinarily on
duty for a regular shift and on call during the other
hours of the day. X is required to use the unmarked
rescue squad vehicle to commute to X’s home in
City M. The rescue squad’s official policy regarding
unmarked rescue squad vehicles prohibits personal
use (other than commuting) of the vehicles outside
the city limits. When not using the vehicle on the
job, X uses the vehicle only for commuting, personal
errands while commuting, and personal errands
within City M. All use of the vehicle by X conforms
to the requirements of paragraph (k)(7) of this section. Therefore, the value of that use is excluded
from X’s gross income as a working condition fringe
and the vehicle is not subject to the substantiation
requirements of section 274(d).
*****
(m) Applicability date. This section
applies to expenses paid or incurred after
December 31, 1997. However, paragraph
796
(j)(3) of this section applies to expenses
paid or incurred after September 30, 2002,
and paragraph (k) of this section applies
to clearly marked public safety officer
vehicles, as defined in paragraph (k)(3)
of this section, only with respect to uses
occurring after May 19, 2010. The rules of
paragraphs (k)(2)(ii)(S), (k)(7) and (k)(9)
(v) of this section apply to taxable years
ending on or after March 20, 2026.
Frank J. Bisignano,
Chief Executive Officer.
Approved: February 17, 2026.
Kenneth J. Kies,
Assistant Secretary of the Treasury (Tax
Policy).
(Filed by the Office of the Federal Register March
19, 2026, 8:45 a.m., and published in the issue of the
Federal Register for March 20, 2026, 91 FR 13500)
Bulletin No. 2026–15
Part III
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2026-19
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest rate on 30-year Treasury securities
under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to single-employer plans (except for CSEC plans
Applicable Month
March 2026
under § 414(y)) pursuant to § 412. Section
430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under this
provision, present value is generally determined using three 24-month average interest rates (“segment rates”), each of which
applies to cash flows during specified periods. To the extent provided under § 430(h)
(2)(C)(iv), these segment rates are adjusted
by the applicable percentage of the 25-year
average segment rates for the period ending
September 30 of the year preceding the calendar year in which the plan year begins.1
However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates.
Section 1.430(h)(2)-1(d) provides
rules for determining the monthly corporate bond yield curve, and § 1.430(h)
(2)-1(c) provides rules for determining
the 24-month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Consistent with the methodology specified in
§ 1.430(h)(2)-1(d), the monthly corporate
bond yield curve derived from February
2026 data is in Table 2026-2 at the end
of this notice. The spot first, second, and
third segment rates for the month of February 2026 are, respectively, 3.96, 5.15,
and 6.11.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. Those percentages are
95% and 105% for plan years beginning
in 2025 and 2026. For this purpose, any
25-year average segment rate that is less
than 5% is deemed to be 5%. The 25-year
average segment rates for plan years
beginning in 2025 and 2026 were published in Notice 2024-67, 2024-41 I.R.B.
726 and Notice 2025-47, 2025-40 I.R.B.
441, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for March
2026 without adjustment for the 25-year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
First Segment
Second Segment
Third Segment
4.50
5.26
5.81
The adjusted 24-month average segment rates set forth in the chart below
reflect § 430(h)(2)(C)(iv) of the Code. The
24-month averages applicable for March
2026, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average segment rates in accordance with § 430(h)(2)
(C)(iv), are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning In
Applicable Month
First Segment
Second Segment
Third Segment
2025
March 2026
4.75
5.26
5.81
2026
March 2026
4.75
5.25
5.81
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Section 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation
described in § 431(c)(6)(A), based on the
plan’s current liability. Section 431(c)
(6)(E)(ii)(I) provides that the interest
rate used to calculate current liability for
this purpose must be no more than 5 percent above and no more than 10 percent
below the weighted average of the rates
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
1
Bulletin No. 2026–15
797
April 6, 2026
of interest on 30-year Treasury securities
during the four-year period ending on the
last day before the beginning of the plan
year. Notice 88-73, 1988-2 C.B. 383,
provides guidelines for determining the
weighted average interest rate. The rate
of interest on 30-year Treasury securities
for February 2026 is 4.76 percent. The
Service determined this rate as the average of the daily determinations of yield
on the 30-year Treasury bond maturing
in November 2055 determined each day
through February 11, 2026 and the yield
on the 30-year Treasury bond maturing in
February 2056 determined each day for
the balance of the month. For plan years
beginning in March 2026, the weighted
average of the rates of interest on 30-year
Treasury securities and the permissible
range of rates used to calculate current
liability are as follows:
For Plan Years Beginning In
Treasury Weighted Average Rates
30-Year Treasury Weighted Average
Permissible Range 90% to 105%
March 2026
4.43
3.99 to 4.65
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Section 1.417(e)-1(d)(3) provides guidelines for determining the min-
imum present value segment rates. Pursuant to that section, the minimum present
value segment rates determined for February 2026 are as follows:
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
Month
February 2026
Minimum Present Value Segment Rates
First Segment
Second Segment
3.96
5.15
DRAFTING INFORMATION
The principal author of this notice
is Tom Morgan of the Office of Associ-
April 6, 2026
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
798
Third Segment
6.11
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Tony Montanaro at
626-927-1475 (not toll-free calls).
Bulletin No. 2026–15
Table 2026-2
Monthly Yield Curve for February 2026
Derived from February 2026 Data
Maturity
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
5.0
5.5
6.0
6.5
7.0
7.5
8.0
8.5
9.0
9.5
10.0
10.5
11.0
11.5
12.0
12.5
13.0
13.5
14.0
14.5
15.0
15.5
16.0
16.5
17.0
17.5
18.0
18.5
19.0
19.5
20.0
Yield
3.76
3.79
3.82
3.86
3.91
3.96
4.02
4.08
4.15
4.22
4.29
4.37
4.45
4.52
4.60
4.67
4.74
4.81
4.88
4.94
5.01
5.06
5.12
5.17
5.22
5.26
5.31
5.35
5.38
5.42
5.45
5.49
5.52
5.55
5.57
5.60
5.62
5.65
5.67
5.69
Maturity
20.5
21.0
21.5
22.0
22.5
23.0
23.5
24.0
24.5
25.0
25.5
26.0
26.5
27.0
27.5
28.0
28.5
29.0
29.5
30.0
30.5
31.0
31.5
32.0
32.5
33.0
33.5
34.0
34.5
35.0
35.5
36.0
36.5
37.0
37.5
38.0
38.5
39.0
39.5
40.0
Bulletin No. 2026–15
Yield
5.72
5.74
5.76
5.78
5.80
5.81
5.83
5.85
5.87
5.88
5.90
5.91
5.93
5.94
5.95
5.97
5.98
5.99
6.00
6.01
6.02
6.03
6.04
6.05
6.05
6.06
6.07
6.08
6.08
6.09
6.10
6.10
6.11
6.12
6.12
6.13
6.14
6.14
6.15
6.15
Maturity
40.5
41.0
41.5
42.0
42.5
43.0
43.5
44.0
44.5
45.0
45.5
46.0
46.5
47.0
47.5
48.0
48.5
49.0
49.5
50.0
50.5
51.0
51.5
52.0
52.5
53.0
53.5
54.0
54.5
55.0
55.5
56.0
56.5
57.0
57.5
58.0
58.5
59.0
59.5
60.0
Yield
6.16
6.16
6.17
6.17
6.18
6.18
6.19
6.19
6.19
6.20
6.20
6.21
6.21
6.22
6.22
6.22
6.23
6.23
6.23
6.24
6.24
6.24
6.25
6.25
6.25
6.26
6.26
6.26
6.27
6.27
6.27
6.27
6.28
6.28
6.28
6.28
6.29
6.29
6.29
6.29
799
Maturity
60.5
61.0
61.5
62.0
62.5
63.0
63.5
64.0
64.5
65.0
65.5
66.0
66.5
67.0
67.5
68.0
68.5
69.0
69.5
70.0
70.5
71.0
71.5
72.0
72.5
73.0
73.5
74.0
74.5
75.0
75.5
76.0
76.5
77.0
77.5
78.0
78.5
79.0
79.5
80.0
Yield
6.30
6.30
6.30
6.30
6.30
6.31
6.31
6.31
6.31
6.32
6.32
6.32
6.32
6.32
6.33
6.33
6.33
6.33
6.33
6.33
6.34
6.34
6.34
6.34
6.34
6.34
6.35
6.35
6.35
6.35
6.35
6.35
6.35
6.36
6.36
6.36
6.36
6.36
6.36
6.36
Maturity
80.5
81.0
81.5
82.0
82.5
83.0
83.5
84.0
84.5
85.0
85.5
86.0
86.5
87.0
87.5
88.0
88.5
89.0
89.5
90.0
90.5
91.0
91.5
92.0
92.5
93.0
93.5
94.0
94.5
95.0
95.5
96.0
96.5
97.0
97.5
98.0
98.5
99.0
99.5
100.0
Yield
6.37
6.37
6.37
6.37
6.37
6.37
6.37
6.37
6.38
6.38
6.38
6.38
6.38
6.38
6.38
6.38
6.39
6.39
6.39
6.39
6.39
6.39
6.39
6.39
6.39
6.39
6.40
6.40
6.40
6.40
6.40
6.40
6.40
6.40
6.40
6.40
6.40
6.41
6.41
6.41
April 6, 2026
EXTENSION OF
TEMPORARY RELIEF
UNDER SECTION 1.10121(j)(3)(ii)
Notice 2026-20
SECTION 1. PURPOSE
This notice extends the temporary
relief provided in section 4.02 of Notice
2025-7, 2025-5 I.R.B. 524 (January 27,
2025), for an additional year. Specifically,
this notice allows eligible taxpayers to use
certain alternative methods for making an
adequate identification, within the meaning of § 1.1012-1(j)(3)(ii),1 with respect to
units of a digital asset held in the custody
of a broker that are sold, disposed of, or
transferred during the relief period specified in this notice.
SECTION 2. BACKGROUND
Section 1012(c)(1) provides that, in the
case of the sale, exchange, or other disposition of a specified security on or after
the applicable date, the conventions prescribed by regulations under that section
must be applied on an account-by-account
basis. Section 1012(c)(3) provides that, for
purposes of section 1012, the terms “specified security” and “applicable date” have
the same definitions given to those terms
in section 6045(g)(3). Section 80603 of
the Infrastructure Investment and Jobs
Act, Pub. L. No. 117-58, 135 Stat. 429,
1339 (2021), expanded the definition of
a specified security in section 6045(g)(3)
to include digital assets. Section 80603
had an applicable date of January 1, 2023.
Section 6045(g)(3)(D) generally defines a
digital asset, for purposes of information
reporting by brokers, as any digital representation of value which is recorded on a
cryptographically secured distributed ledger or any similar technology as specified
by the Secretary.
On August 29, 2023, the Department
of the Treasury (Treasury Department)
and the Internal Revenue Service (IRS)
1
published in the Federal Register (88 FR
59576) proposed regulations (2023 proposed regulations) under sections 6045,
1001, 1012, and other sections of the
Code. The 2023 proposed regulations, in
part, would have clarified the statutory
requirements for determining and identifying the cost basis of digital assets.
Consistent with section 1012(c), the proposed regulations would have required
basis determinations on an account-byaccount basis.
On July 9, 2024, the Treasury Department and the IRS published in the Federal
Register (89 FR 56480) T.D. 10000 (final
regulations). Section 1.1012-1(j) of the
final regulations provides ordering rules
for determining which units of the same
digital asset should be treated as sold, disposed of, or transferred when a taxpayer
holds multiple units of that same digital
asset within the same wallet that were
acquired on different dates or at different
prices. Paragraph (j) generally applies
separate rules depending on whether or
not the units are held by the taxpayer in
the custody of a broker.
For digital asset units held in the custody of a taxpayer’s broker, § 1.1012-1(j)
(3)(ii) generally permits a taxpayer to
make an adequate identification of the
units to be sold, disposed of, or transferred. Adequate identification is made
if, no later than the date and time of the
sale, disposition, or transfer, the taxpayer
specifies to the custodial broker with
custody of the digital assets the particular units of the digital asset to be sold,
disposed of, or transferred. The taxpayer
may identify units by reference to any
identifier, such as purchase date and time
or purchase price, that the broker designates as sufficiently specific to identify
the units sold, disposed of, or transferred.
Section 1.1012-1(j)(3)(ii) also permits
taxpayers to make an adequate identification of such units by using a standing
order or instruction communicated to
their custodial broker. Further, if the custodial broker offers taxpayers only one
method of making a specific identification—for example, by the earliest date on
which units of the same digital asset were
acquired, the latest date on which units
of the same digital asset were acquired,
or the highest basis—§ 1.1012-1(j)(3)(ii)
treats such method as a standing order or
instruction.
For units held in the custody of a
broker for which the taxpayer does not
make an adequate identification of the
units sold, disposed of, or transferred
in accordance with § 1.1012-1(j)(3)(ii),
§ 1.1012-1(j)(3)(i) treats such units as
sold, disposed of, or transferred in order
of time from the earliest date on which
units of that same digital asset held in the
custody of the broker were acquired by
the taxpayer (“FIFO rule”). Regardless
of whether the taxpayer makes an adequate identification, in the case of digital assets exchanged for different digital
assets, § 1.1012-1(j)(3)(iii) deems any
units withheld, either for the broker’s
backup withholding obligations under
section 3406, or for payment of services
described in § 1.1001-7(b)(1)(ii) (digital
asset transaction costs), as coming from
the units received in the exchange.
Separate ordering rules, found in
§ 1.1012-1(j)(1) and (2), prescribe how
units not held in the custody of a broker
are identified as the units sold, disposed
of, or transferred. Section 1.1012-1(j)(6)
provides that § 1.1012-1(j) applies to all
acquisitions and dispositions of digital
assets on or after January 1, 2025.
Contemporaneously with the issuance of § 1.1012-1(j), the IRS issued
Rev. Proc. 2024-28, 2024-31 I.R.B.
326 (July 29, 2024), which provides
guidance to taxpayers regarding how to
transition from a universal or multi-wallet basis allocation methodology to a
wallet-by-wallet or account-by-account
basis allocation methodology. Specifically, subject to certain requirements,
Rev. Proc. 2024-28 provides a safe harbor for taxpayers to allocate their units
of unattached basis in digital assets
acquired before January 1, 2025, to a
digital asset wallet or account that holds
the same number of remaining digital asset units based on the taxpayer’s
records of such unattached basis and
remaining units so long as the alloca-
Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code (Code) or the Income Tax Regulations (26 CFR part 1).
April 6, 2026
800
Bulletin No. 2026–15
tion is reasonable. Rev. Proc. 2024-28
permits taxpayers either to make a specific unit allocation or to make a global
allocation in order to allocate units of
unattached basis, subject to various conditions. For each type of digital asset,
the allocation generally is required to be
completed by the date of the first sale
of that type of digital asset on or after
January 1, 2025.
In response to concerns expressed by
some custodial brokers, the IRS issued
Notice 2025-7, which temporarily allows
taxpayers to use additional methods
for making an adequate identification
within the meaning of § 1.1012-1(j)(3)
(ii). Notice 2025-7 provides that, during
calendar year 2025, which the notice
refers to as the relief period, taxpayers
can make adequate identifications of
units of digital assets sold, disposed of,
or transferred from the taxpayer’s units
held in the custody of a broker by identifying the particular units or recording
a standing order in the taxpayer’s books
and records, temporarily relieving taxpayers of the requirement in § 1.10121(j)(3)(ii) to communicate identifications
to the broker. The notice also provides
that if a taxpayer makes an adequate
identification under the notice, the rule in
§ 1.1012-1(j)(3)(ii), which treats taxpayers whose broker offers only one method
of making a specific identification as having made a standing order or instruction,
does not apply. Taxpayers relying on the
safe harbor under Rev. Proc. 2024-28 can
rely on the temporary relief in the notice
only after the requirements of Rev. Proc.
2024-28 have been satisfied. The temporary relief described in Notice 2025-7
does not apply to digital asset units not
held in the custody of a broker.
Certain digital asset custodial brokers
have informed the Treasury Department
and the IRS that they have built and
implemented systems and procedures to
report gross proceeds for digital asset
transactions carried out in 2025 and will
report those transactions to the IRS and
customers in 2026, and that those brokers
also have made good faith efforts to build
and implement systems and procedures
that will enable those brokers to accept
and process specific identification or
standing order instructions from customers in 2026. The Treasury Department
Bulletin No. 2026–15
and the IRS understand that many custodial brokers have substantially completed
much of the work necessary to accept
specific identifications from customers
but are not currently ready to accept specific identifications (other than standing
orders) from customers. Notwithstanding the temporary relief provided in
Notice 2025-7, some of those custodial
brokers do not have in place the technology needed to accept specific instructions communicated by taxpayers but
are expected to complete building and
implementing the systems necessary to
do so during 2026. Consequently, some
taxpayers may be temporarily unable to
make adequate identifications in conformity with § 1.1012-1(j)(3)(ii), with the
result that any units in the custody of
such brokers that are sold, disposed of,
or transferred before the necessary systems are in place would be determined
under the FIFO rule without further temporary relief. To avoid this result, this
notice extends the relief period specified
in Notice 2025-7 through December 31,
2026.
This notice extends the temporary
relief provided by Notice 2025-7, allowing taxpayers to use additional methods
for making an adequate identification
within the meaning of § 1.1012-1(j)(3)
(ii) during the relief period, as defined
in section 3.03 of this notice. This notice
does not prohibit taxpayers from complying with the requirements of § 1.10121(j)(3)(ii). In addition, this notice does
not affect how the safe harbor described
in Rev. Proc. 2024-28 applies and does
not affect the requirement for brokers to
report gross proceeds on the Form 1099DA beginning in 2025. Taxpayers relying
on the safe harbor described in Rev. Proc.
2024-28 may also rely on the temporary
relief described in section 4.02 of this
notice once the applicable requirements
of Rev. Proc. 2024-28 have been satisfied,
including, in the case of taxpayers making
a global allocation, the completion of the
global allocation.
A method of specifically identifying
the units of a digital asset sold, disposed
of, or transferred (for example, by the earliest acquired, the latest acquired, or the
highest basis) is not a method of accounting to which section 446 or section 481
apply. See § 1.1012-1(j)(4).
801
As with the temporary relief provided
in Notice 2025-7, the temporary relief
described in this notice does not apply
for purposes of the § 1.6045-1 information reporting rules for digital assets.
Consequently, for 2026 transactions,
the acquisition date and basis reported
by a broker to a taxpayer with respect to
a sale, disposition or transfer of digital
assets may not match the lot identification and basis of that sale, disposition
or transfer on the taxpayer’s books and
records. Similarly, as with the temporary relief provided in Notice 2025-7,
the relief provided under this notice
does not apply to digital asset units not
held in the custody of a broker.
SECTION 3. DEFINITIONS
Except as otherwise provided, the following definitions apply solely for purposes of this notice:
.01 Digital Asset. The term “digital asset” has the meaning provided in
§ 1.1012-1(j).
.02 Broker. The term “broker” has the
meaning provided in § 1.1012-1(j).
.03 Relief Period. The term “relief
period” means the period beginning on
January 1, 2025, and ending on December
31, 2026.
SECTION 4. TEMPORARY RELIEF
.01 Scope. The temporary relief
described in section 4.02 of this notice
is available only with respect to units of
a digital asset held in the custody of a
broker that are sold, disposed of, or transferred during the relief period.
.02 Temporary Relief under § 1.10121(j)(3)(ii). A taxpayer may make an adequate identification during the relief period
of a taxpayer’s units of a digital asset to be
sold, disposed of, or transferred from the
taxpayer’s units held in the custody of a
broker by:
(1) Identifying, no later than the date
and time of the sale, disposition, or
transfer, on the taxpayer’s books
and records, the particular units to
be sold, disposed of, or transferred
by reference to any identifier, such
as purchase date and time or the purchase price for the unit, that is sufficient to identify the basis and holding
April 6, 2026
period of the units sold, disposed of,
or transferred; or
(2) Recording a standing order on the
taxpayer’s books and records, provided that the recorded standing
order includes sufficient information
to identify any digital asset units
sold, disposed of, or transferred and
is entered into the taxpayer’s books
and records before the units covered
by the order are sold, disposed of, or
transferred.
.03 Nonapplication of § 1.1012-1(j)
(3)(ii). If a taxpayer makes an adequate
identification under subsection 4.02 of
this notice, the rule in § 1.1012-1(j)(3)
(ii), which treats taxpayers whose broker offers only one method of making a
specific identification as having made
a standing order or instruction, does not
apply during the relief period.
.04 Safe harbor under Rev. Proc. 202428. Taxpayers relying on the safe harbor
under Rev. Proc. 2024-28 may rely on the
temporary relief described in section 4.02
of this notice only after the applicable
requirements of Rev. Proc. 2024-28 have
been satisfied.
.05 Adequate Identification. If the taxpayer has made an adequate identification
on its books and records of the digital
asset units sold, disposed of or transferred
during 2026 pursuant to sections 4.014.04 of this notice, for Federal income
tax purposes the units sold, disposed of
or transferred by the taxpayer are the ones
identified in the taxpayer’s books and
records regardless of whether the information reported by the broker to the taxpayer
matches the taxpayer’s books and records.
If the taxpayer has instead specified to its
broker, no later than the date and time of
the sale, disposition, or transfer, the particular units of the digital asset to be sold,
disposed of, or transferred by reference
to any identifier that the broker designates as sufficiently specific to allow it to
determine the basis and holding period of
those units (including by communicating
a standing order to the broker), for Federal income tax purposes the units sold,
April 6, 2026
disposed of or transferred by the taxpayer
are the ones specified by the taxpayer to
the broker
SECTION 5. RELIANCE
Taxpayers may rely on the temporary
relief described in section 4.02 of this
notice only for the duration of the relief
period, as defined in section 3.03 of this
notice. Accordingly, taxpayers may not
rely on the temporary relief described
in section 4.02 of this notice to identify
units held in the custody of the broker
as the units sold, disposed of, or transferred in the case of sales, dispositions
and transfers made after the relief period
ends.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Notice 2025-7 is modified.
SECTION 7. DRAFTING
INFORMATION
The principal author of this notice is
Thomas Brown of the Office of Associate
Chief Counsel (Income Tax and Accounting). For further information regarding
this notice, contact Mr. Brown at (202)
317-4718 (not a toll-free number).
2026 Calendar Year
Resident Population
Figures
Notice 2026-22
This notice advises State and local
housing credit agencies that allocate
low-income housing tax credits under § 42
of the Internal Revenue Code, and States
and other issuers of tax-exempt private
activity bonds under § 141, of the population figures to use in calculating: (1)
the 2026 calendar year population-based
802
component of the State housing credit
ceiling (Credit Ceiling) under § 42(h)(3)
(C)(ii); (2) the 2026 calendar year volume
cap (Volume Cap) under § 146; and (3) the
2026 volume limit (Volume Limit) under
§ 142(k)(5).
Generally, the population-based component of both the Credit Ceiling and
the Volume Cap are determined under
§ 146(j), which requires determining the
population figures for any calendar year
on the basis of the most recent census estimate of the resident population of a State
(or issuing authority) released by the U.S.
Census Bureau before the beginning of the
calendar year. Similarly, § 142(k)(5) bases
the Volume Limit on the State population.
Sections 42(h)(3)(H) and 146(d)(2)
require adjusting for inflation the population-based component of the Credit
Ceiling and the Volume Cap. The Credit
Ceiling adjustment for the 2026 calendar year is in Rev. Proc. 2025-32; 202545 I.R.B. 695. Section 4.08 of Rev. Proc.
2025-32 provides that, for calendar year
2026, the amount for calculating the
Credit Ceiling under § 42(h)(3)(C)(ii) is
the greater of $3.416 multiplied by the
State population, or $3,953,600. Further, section 4.19 of Rev. Proc. 2025-32
provides that the amount for calculating
the Volume Cap under § 146(d)(1) for
calendar year 2026 is the greater of $135
multiplied by the State population, or
$397,625,000.
For the 50 states, the District of Columbia, and Puerto Rico, the population figures for calculating the Credit Ceiling, the
Volume Cap, and the Volume Limit for the
2026 calendar year are the resident population estimates released electronically
by the U.S. Census Bureau on January
27, 2026, and described in Press Release
CB26-20. For American Samoa, Guam,
the Northern Mariana Islands, and the
U.S. Virgin Islands, the population figures
for the 2026 calendar year are the 2025
midyear population figures in the U.S.
Census Bureau’s International Data Base.
For convenience, these figures are
reprinted below.
Bulletin No. 2026–15
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Mariana Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands, U.S.
Washington
West Virginia
Wisconsin
Wyoming
Bulletin No. 2026–15
Resident Population Figures
5,193,088
737,270
43,268
7,623,818
3,114,791
39,355,309
6,012,561
3,688,496
1,059,952
693,645
23,462,518
11,302,748
169,691
1,432,820
2,029,733
12,719,141
6,973,333
3,238,387
2,977,220
4,606,864
4,618,189
1,414,874
6,265,347
7,154,084
10,127,884
5,830,405
2,954,160
6,270,541
1,144,694
2,018,006
3,282,188
1,415,342
9,548,215
2,125,498
20,002,427
11,197,968
799,358
50,946
11,900,510
4,123,288
4,273,586
13,059,432
3,184,835
1,114,521
5,570,274
935,094
7,315,076
31,709,821
3,538,904
644,663
8,880,107
103,792
8,001,020
1,766,147
5,972,787
588,753
803
April 6, 2026
The principal authors of this notice are
Waheed M. Olayan, Office of the Associate Chief Counsel (Energy, Credits, and
Excise Tax), and Brian Choi, Office of the
Associate Chief Counsel (Financial Institutions and Products). For further information regarding this notice, please contact Waheed M. Olayan at (202) 317-6239
(not a toll-free call).
Public Recommendations
Invited on Items to be
Included on the 2026-2027
Priority Guidance Plan
Notice 2026-23
The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) invite the public to
submit recommendations for items to be
included on the 2026-2027 Priority Guidance Plan.
The Treasury Department’s Office of
Tax Policy and the IRS use the Priority
Guidance Plan each year to identify and
prioritize the tax issues that should be
addressed through regulations, revenue
rulings, revenue procedures, notices, and
other published administrative guidance.
The 2026-2027 Priority Guidance Plan
will identify guidance projects that the
Treasury Department and the IRS intend
to actively work on as priorities during the
period from July 1, 2026, through June 30,
2027.
The Treasury Department and the IRS
recognize the importance of public input in
formulating a Priority Guidance Plan that
focuses resources on guidance items that
are most important to taxpayers and tax
administration. Published guidance plays
an important role in increasing voluntary
compliance by helping to clarify ambiguous areas of the tax law. The published
guidance process is most successful if the
Treasury Department and the IRS have the
benefit of the experience and knowledge
of taxpayers and practitioners who must
apply the rules implementing the tax laws.
In reviewing recommendations and
selecting additional projects for inclusion
on the 2026-2027 Priority Guidance Plan,
April 6, 2026
the Treasury Department and the IRS will
consider the following:
1. Whether the recommended guidance
relates to recently enacted legislation,
such as Public Law 119-21, 139 Stat. 72
(July 4, 2025), commonly known as the
One, Big, Beautiful Bill Act;
2. Whether taxpayers have identified
that the recommended guidance relates to
regulations potentially described in Executive Order 14219 (90 FR 10583) Section
2(a):
(i) unconstitutional regulations and
regulations that raise serious constitutional difficulties, such as exceeding the
scope of the power vested in the Federal
Government by the Constitution;
(ii) regulations that are based on unlawful delegations of legislative power;
(iii) regulations that are based on anything other than the best reading of the
underlying statutory authority or prohibition;
(iv) regulations that implicate matters
of social, political, or economic significance that are not authorized by clear statutory authority;
(v) regulations that impose significant
costs upon private parties that are not outweighed by public benefits;
(vi) regulations that harm the national
interest by significantly and unjustifiably
impeding technological innovation, infrastructure development, disaster response,
inflation reduction, research and development, economic development, energy
production, land use, and foreign policy
objectives; and
(vii) regulations that impose undue
burdens on small business and impede private enterprise and entrepreneurship.
3. Whether the recommendation involves
existing regulations or other guidance that is
outdated, unnecessary, ineffective, insufficient, or unnecessarily burdensome and that
should be modified, streamlined, expanded,
replaced, or withdrawn;
4. Whether the recommended guidance
reduces controversy and lessens the burden on taxpayers or the IRS;
5. Whether the recommended guidance
would be in accordance with Executive
Order 14192 (90 FR 9065) or other executive orders;
6. Whether the recommended guidance
resolves significant issues relevant to a
broad class of taxpayers;
804
7. Whether the recommended guidance
promotes sound tax administration;
8. Whether the IRS can administer
the recommended guidance on a uniform
basis; and
9. Whether the recommended guidance
can be drafted in a manner that will enable
taxpayers to easily understand and apply
the guidance.
Please submit recommendations for
guidance by Friday, May 29, 2026, for
possible inclusion on the original 20262027 Priority Guidance Plan. Taxpayers
may, however, submit recommendations
for guidance at any time during the year.
The Treasury Department and the IRS
will update the 2026-2027 Priority Guidance Plan periodically to reflect additional
guidance that the Treasury Department
and the IRS intend to publish or have published during the plan year. The periodic
updates allow the Treasury Department
and the IRS to respond in a timely manner
to the need for additional guidance that
may arise during the plan year.
Taxpayers are not required to submit recommendations for guidance in
any particular format. Taxpayers should,
however, briefly describe the recommended guidance and explain the need
for the guidance. In addition, taxpayers
may include an analysis of how the issue
should be resolved. For recommendations
to modify, streamline, or withdraw existing regulations or other guidance, taxpayers should explain how the changes would
reduce taxpayer cost and/or burden, benefit tax administration, or address issues
described in Executive Order 14219 Sections 2(a)(i) – (vii). It would be helpful
if taxpayers suggesting more than one
guidance project prioritize the projects
by order of importance. If a large number
of projects are being suggested, it would
be helpful if the projects were grouped
by subject matter and then in terms of
high, medium, or low priority. Requests
for guidance in the form of petitions for
rulemaking will be considered with other
recommendations for guidance in accordance with the considerations described in
this notice.
Taxpayers are strongly encouraged to
submit recommendations for guidance
electronically via the Federal eRulemaking Portal at https://www.regulations.gov
(type IRS-2026-0364 in the search field
Bulletin No. 2026–15
on the regulations.gov homepage to find
this notice and submit recommendations).
Taxpayers submitting recommendations
by mail should send them to:
Internal Revenue Service
Attn: CC:PA:01:PR (Notice 2026-23)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
All recommendations for guidance
submitted by the public in response to this
notice will be available for public inspection and copying in their entirety. For
further information regarding this notice,
contact the Office of the Associate Chief
Counsel (Procedure and Administration)
at (202) 317-3400 (not a toll-free call).
26 CFR 601.601. Rules and regulations.
(Also: Part I, §§ 163, 168.)
Rev. Proc. 2026-17
SECTION 1. PURPOSE
.01 Withdrawal of a § 163(j) election.
This revenue procedure provides guidance
under § 163(j)1 regarding the withdrawal
of an election under § 163(j)(7)(B) and
§ 1.163(j)-9 to be an electing real property trade or business, an election under
§ 163(j)(7)(C) and § 1.163(j)-9 to be an
electing farming business, and an election under § 1.163(j)-1(b)(15)(iii) to be
an excepted regulated utility trade or business, for purposes of the business interest
deduction limitation under § 163(j). This
revenue procedure allows certain taxpayers to withdraw such an election for the
taxable year in which the election was
made. This revenue procedure also allows
a taxpayer that withdraws one of these
elections to make a late election not to
deduct the additional first-year depreciation for certain property.
.02 Revoking or making a CFC
group election. In addition, this revenue procedure provides guidance under
§ 1.163(j)-7(e) allowing a taxpayer to
revoke or make a controlled foreign corporation (CFC) group election without
regard to the 60-month limitation under
§ 1.163(j)-7(e)(5)(ii) for the first specified
period of a specified group beginning after
December 31, 2024.
.03 Amended partnership returns. This
revenue procedure allows eligible partnerships to file amended partnership returns
for taxable years beginning in 2022, 2023,
and 2024 using a Form 1065, U.S. Return
of Partnership Income (Form 1065), with
the “Amended Return” box checked,
and to issue an amended Schedule K-1,
Partner’s Share of Income, Deductions,
Credits, etc. (Schedule K-1), to each of
its partners. Eligible partnerships subject
to the rules of subchapter C of chapter
63 of the Code (BBA partnerships) may
file an administrative adjustment request
under § 6227 (AAR). BBA partnerships
satisfying the requirements of section 7 of
this revenue procedure may opt to file an
amended Form 1065 and furnish amended
Schedules K-1 instead of filing an AAR.
SECTION 2. BACKGROUND
.01 Section 163(j) prior to amendment
by the OBBBA.
(1) On December 22, 2017, § 163(j)
was amended by § 13301(a) of Public
Law 115-97, 131 Stat. 2054 (Dec. 22,
2017), commonly known as the Tax Cuts
and Jobs Act (TCJA). Section 163(j), as
amended by § 13301(a) of the TCJA, provides rules limiting the amount of business
interest that can be deducted for taxable
years beginning after December 31, 2017,
to the sum of: (a) the taxpayer’s business
interest income for the taxable year; (b) 30
percent of the taxpayer’s adjusted taxable
income (ATI) for the taxable year; and (c)
the taxpayer’s floor plan financing interest
expense for the taxable year.
(2) Under § 163(j)(8) as amended by
§ 13301(a) of the TCJA, ATI is the taxable income of the taxpayer computed
without regard to certain items, including
any deduction allowable for depreciation,
amortization, or depletion for taxable
years beginning before January 1, 2022.
(3) The § 163(j) limitation applies
to taxpayers with business interest, as
defined in § 163(j)(5), except for taxpayers, other than tax shelters under § 448(a)
(3), that meet the gross receipts test in
§ 448(c). Section 163(j)(5), as amended
by § 13301 of the TCJA, defines the term
“business interest” to mean any interest
expense properly allocable to a trade or
business (other than investment interest
within the meaning of § 163(d)).
(4) Section 163(j)(7)(A)(ii) through
(iv) provides that, for purposes of
§ 163(j), the term “trade or business”
does not include an “electing real property
trade or business” (as defined in § 163(j)
(7)(B)), an “electing farming business”
(as defined in § 163(j)(7)(C)), or a “regulated utility trade or business” (as defined
in § 1.163(j)-1(b)(15)(iii)). Thus, interest
expense that is properly allocable to any
such trade or business is not properly
allocable to a trade or business under
§ 163(j) and is not business interest that
is subject to the limitation in § 163(j)(1).
Section 163(j)(7)(B) and (C), as amended
by § 13301 of the TCJA, provide that the
elections to be an electing real property
trade or business and an electing farming
business are made in the time and manner
prescribed by the Secretary of the Treasury or the Secretary’s delegate (Secretary) and, once made, are irrevocable.
(5) On March 27, 2020, § 163(j) was
further amended by § 2306 of the Coronavirus Aid, Relief, and Economic Security
Act (CARES Act), Public Law 116-136,
134 Stat. 281 (March 27, 2020). Section
2306 of the CARES Act temporarily
increased the ATI percentage in § 163(j)
(1) from 30 percent to 50 percent for taxable years beginning in 2019 and 2020.
(6) On April 27, 2020, the Department
of the Treasury (Treasury Department) and
the Internal Revenue Service (IRS) published Rev. Proc. 2020-22, 2020-18 I.R.B.
745. Rev. Proc. 2020-22 provides, among
other procedures, the time and manner for
withdrawing an election under § 163(j)(7)
(B) to be an electing real property trade
or business, or under § 163(j)(7)(C) to be
an electing farming business, for taxable
years beginning in 2018, 2019, or 2020.
(7) On April 27, 2020, the Treasury
Department and the IRS published Rev.
Proc. 2020-23, 2020-18 I.R.B. 749. Rev.
Proc. 2020-23 provides that eligible partnerships meeting certain conditions may
Unless otherwise specified, all “§” references are to sections of the Internal Revenue Code (Code), the Income Tax Regulations (26 CFR Part 1), or the Procedure and Administration Regulations (26 CFR Part 301).
1
Bulletin No. 2026–15
805
April 6, 2026
file amended partnership returns for taxable years beginning in 2018 and 2019.
(8) On September 14, 2020, the Treasury Department and the IRS published
final regulations (TD 9905) in the Federal Register (85 FR 56686) adopting
§§ 1.163(j)-1(b)(15)(iii) and 1.163(j)-9.
(a) Excepted regulated utility trade or
business. Section 1.163(j)-1(b)(15)(iii)
permits certain taxpayers to elect to be
treated as an excepted regulated utility
trade or business. Interest expense that
is properly allocable to any such trade
or business is not properly allocable to a
trade or business under § 163(j) and is not
business interest that is subject to the limitation in § 163(j)(1). Taxpayers eligible to
elect to be treated as an excepted regulated
utility trade or business are those that (i)
are not an excepted regulated utility trade
or business described in § 1.163(j)-1(b)
(15)(i)(A) or (C), and (ii) provide electrical energy, water, sewage disposal services, gas or steam through a local distribution system, or transportation of gas or
steam by pipeline, to the extent that the
rates are established or approved by a regulatory body described in § 1.163(j)-1(b)
(15)(i)(A)(2)(i). Section 1.163(j)-1(b)
(15)(iii) provides rules and procedures
for making the election to be an excepted
regulated utility trade or business. Section 1.163(j)-1(b)(15)(iii)(B)(1) provides
that an election under § 1.163(j)-1(b)(15)
(iii) is made with respect to each eligible
trade or business of the taxpayer, applies
only to the trade or business for which the
election is made, and applies to the taxable year in which the election is made
and all subsequent taxable years. Section
1.163(j)-1(b)(15)(iii)(B)(2) provides that
an election under § 1.163(j)-1(b)(15)(iii)
is irrevocable. Section 1.163(j)-1(b)(15)
(ii)(A) provides that an excepted regulated
utility trade or business cannot claim the
additional first-year depreciation deduction under § 168(k) for any property that
is primarily used in the excepted regulated
utility trade or business.
(b) Electing real property trade or
business and electing farming business.
Section 1.163(j)-9(d)(1) provides that a
taxpayer makes an election under § 163(j)
(7)(B) or § 163(j)(7)(C) to be an electing
real property trade or business or electing
farming business by attaching an election
statement with the information speci-
April 6, 2026
fied in § 1.163(j)-9(d)(2) to the taxpayer’s timely filed original Federal income
tax return, including extensions. Section
1.163(j)-9(c)(1) provides that an election
under § 1.163(j)-9 is made with respect
to each eligible trade or business of the
taxpayer, applies only to such trade or
business for which the election is made,
and applies to the taxable year in which
the election is made and to all subsequent
taxable years.
(9) On January 19, 2021, the Treasury
Department and the IRS published final
regulations (TD 9943) in the Federal
Register (86 FR 5496) that, in relevant
part, provide rules for applying § 163(j)
to foreign corporations and United States
shareholders under § 1.163(j)-7. Under
§ 1.163(j)-7(c)(2), a single § 163(j) limitation is computed for a specified period
(as defined in § 1.163(j)-7(k)(29)) of a
CFC group (that is, a specified group,
within the meaning of § 1.163(j)-7(d)(2)
(i), for which a CFC group election is in
effect). Rules for making and revoking
a CFC group election are provided in
§ 1.163(j)-7(e). Pursuant to § 1.163(j)-7(e)
(5)(iii)-(iv), each designated U.S. person
with respect to a specified group makes or
revokes a CFC group election by attaching
an election statement to its timely filed relevant Federal income tax return or information return, taking into account extensions, if any. Section 1.163(j)-7(k)(12)
provides that the designated U.S. person
with respect to a specified group is either
(i) the specified group parent (if the specified group parent is a qualified U.S. person within the meaning of § 1.163(j)-7(d)
(2)(iv)), or (ii) each controlling domestic
shareholder of the specified group parent
(if the specified group parent is an applicable CFC). Under § 1.163(j)-7(e)(5)(ii), a
CFC group election may be revoked with
respect to any specified period beginning
at least 60 months after the last day of the
specified period for which the CFC group
election was made, and, once a CFC group
election has been revoked, a new election
can be made with respect to any specified period beginning at least 60 months
after the last day of the specified period
for which the CFC group election was
revoked (collectively, the 60-month limitation).
.02 Amendments to § 163(j)(8) made
by the One, Big, Beautiful Bill Act. On
806
July 4, 2025, § 163(j)(8) was amended
by §§ 70303 and 70342 of Public Law
119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful
Bill Act (OBBBA). Section 70303(a)
of the OBBBA amended § 163(j)(8) by
striking “in the case of taxable years
beginning before January 1, 2022,” from
§ 163(j)(8)(A)(v), thereby restoring a
taxpayer’s ability to add back depreciation, amortization, or depletion when
calculating ATI for taxable years beginning after December 31, 2024. Section
70342 of the OBBBA amended § 163(j)
(8)(A) to provide that ATI is computed
without regard to amounts included in
gross income under §§ 951(a), 951A(a),
and 78 (and the portion of the deductions
allowed under §§ 245A(a) (by reason of
§ 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions). The amendment
made by § 70342 of the OBBBA applies
to taxable years beginning after December 31, 2025.
.03 The § 168(k) additional first-year
depreciation deduction.
(1) Under § 168(g)(1)(F) and (G), as
amended by § 13205(a) of the TCJA, an
electing real property trade or business
and electing farming business are required
to use the alternative depreciation system
under § 168(g) for certain types of property under § 163(j)(11) and cannot claim
the additional first-year depreciation
deduction under § 168(k) for those types
of property.
(2) Section 168(k)(2)(D)(i) provides
that the term “qualified property” (that is,
property eligible for the additional firstyear depreciation deduction) does not
include any property to which the alternative depreciation system under § 168(g)
applies, determined (a) without regard
to § 168(g)(7) (relating to the election to
use the alternative depreciation system),
and (b) after the application of § 280F(b)
(relating to listed property with limited
business use).
(3) Section 168(k)(7) allows a taxpayer to elect not to deduct the additional first-year depreciation for any
class of property that is qualified property placed in service during the taxable
year (§ 168(k)(7) election). The rules and
procedures for making the § 168(k)(7)
election are set forth in § 1.168(k)-2(f)
(1). Section 1.168(k)-2(f)(1)(ii) defines
Bulletin No. 2026–15
“class of property” for purposes of
the § 168(k)(7) election. Pursuant to
§ 1.168(k)-2(f)(1)(iii), the § 168(k)(7)
election must be made (a) by the due
date, including extensions, of the Federal income tax return or Form 1065 for
the taxable year in which the qualified
property is placed in service by the taxpayer, and (b) in the manner prescribed
on Form 4562, Depreciation and Amortization (Including Information on Listed
Property), and its instructions.
(4) Section 70301 of the OBBBA
amended § 168(k) to make the additional
first-year depreciation deduction 100 percent and permanent. This amendment is
generally effective for property acquired
after January 19, 2025, and for any specified plant (as defined in § 168(k)(5)(B),
as amended by § 70301 of the OBBBA)
that is planted or grafted after January 19,
2025.
.04 Provisions related to BBA partnerships.
(1) Section 1101(a) of the Bipartisan
Budget Act of 2015 (BBA), P.L. 114-74,
Title XI (November 2, 2015), replaced
subchapter C of chapter 63 of subtitle F
of the Code effective for partnership taxable years beginning after December 31,
2017. Section 1101(c) of the BBA enacted
a centralized partnership audit regime
that, in general, determines, assesses, and
collects tax at the partnership level. The
centralized partnership audit procedures
enacted by the BBA are found at §§ 6221
through 6241. The centralized partnership
audit procedures apply to all partnerships
required to file a return, unless the partnership is eligible to make, and in fact makes,
a valid election under § 6221(b) not to
have those procedures apply. Partnerships
subject to the centralized partnership audit
regime are referred to as “BBA partnerships.”
(2) Section 6031(a) requires every
partnership, except certain foreign partnerships, to file a return for each taxable
year stating the items of its gross income
and the deductions allowable by subtitle A
of the Code and such other information as
required by forms and regulations, including information about the partners in the
partnership. The form filed by partnerships
is Form 1065, which includes Schedules
K‑1. Schedules K-1 report each partner’s
name, taxpayer identification number, and
Bulletin No. 2026–15
distributive share of partnership-related
items and other information related to the
partner’s interest in the partnership. Section 6031(b) requires that a partnership
required to file a return under § 6031(a)
furnish a copy of the Schedule K-1 to each
partner that includes such information as
may be required to be shown by regulations. In general, § 6031(b) also prohibits BBA partnerships from amending the
information required to be furnished to
their partners after the due date of the
return, unless specifically authorized by
the Secretary.
(3) Section 6222(a) requires partners in
a BBA partnership to treat partnership-related items, as defined in § 6241 and the
corresponding regulations, consistently on
the partner’s return with the treatment of
such items by the BBA partnership on its
return. The consistency requirement generally applies to all partners. Consistent
treatment with the partnership generally
requires that partners in a BBA partnership file their returns consistently with the
information reported to them on Schedule
K-1.
.05 Transition rules. This revenue
procedure provides transition guidance
under §§ 163(j) and 168(k) for taxpayers who previously elected to be treated
as an electing real property trade or
business, electing farming business, or
excepted regulated utility trade or business, but who now wish to withdraw the
election in light of the various amendments to §§ 163(j)(8) and 168(k) under
the OBBBA. Section 4 of this revenue
procedure allows certain taxpayers to
withdraw a prior election to be an electing real property trade or business, an
electing farming business, or an excepted
regulated utility trade or business. Section 5 of this revenue procedure allows
a taxpayer withdrawing an election
under section 4 of this revenue procedure to make a late § 168(k)(7) election
with respect to any class of property that
includes depreciable property affected by
the election withdrawn under section 4
of this revenue procedure. Section 6 of
this revenue procedure allows taxpayers
to revoke or make a CFC group election
without regard to the 60-month limitation
under § 1.163(j)-7(e)(5)(ii). Section 7 of
this revenue procedure permits an eligible BBA partnership to file an amended
807
Form 1065 subject to the conditions set
forth in that section
SECTION 3. SCOPE
.01 Section 163(j)(7)(B) and (C) and
§ 1.163(j)-1(b)(15)(iii) elections. Section 4 of this revenue procedure applies
to a taxpayer that made an election under
§ 163(j)(7)(B) and § 1.163(j)-9 to be an
electing real property trade or business,
under § 163(j)(7)(C) and § 1.163(j)-9 to
be an electing farming business, or under
§ 1.163(j)-1(b)(15)(iii) to be an excepted
regulated utility trade or business, on its
timely filed (including extensions) original Federal income tax return or Form
1065 for a taxable year beginning in 2022
(2022 taxable year), 2023 (2023 taxable
year), or 2024 (2024 taxable year) and
now wants to withdraw the election.
The elections described in the preceding
sentence are referred to in this revenue
procedure as “§ 163(j)(7) elections” collectively or as a “§ 163(j)(7) election”
individually. If a taxpayer withdraws an
election pursuant to this revenue procedure, the taxpayer will be treated as if
the election had never been made. The
fact that a taxpayer satisfies the scope
requirement of this section 3 is not a
determination that the taxpayer is a real
property trade or business for purposes of
§§ 162, 212, or 469, a farming business
for purposes of §§ 162, 199A, or 263A,
or a regulated utility trade or business for
purposes of §§ 162, 168, or 501.
.02 Section 168(k)(7) election. Section 5 of this revenue procedure applies
to a taxpayer that (a) is withdrawing
a § 163(j)(7) election under section 4
of this revenue procedure, (b) during
the taxable year of its prior § 163(j)(7)
election or a subsequent taxable year,
placed into service depreciable property, (c) timely filed its Federal income
tax return or Form 1065 for the placedin-service year of such depreciable property on or before March 18, 2026, and
(d) has not yet made, but wants to make,
a late § 168(k)(7) election with respect
to a class of depreciable property that
includes property affected by the withdrawal of the § 163(j)(7) election.
.03 CFC group election. Section 6 of
this revenue procedure applies to a taxpayer that has made or revoked a CFC
April 6, 2026
group election for a specified period of
a specified group beginning on or before
December 31, 2024, and wants to revoke
this election or make a new election,
respectively, for the first specified period
of the specified group beginning after
December 31, 2024, but the 60-month
limitation described in § 1.163(j)-7(e)(5)
(ii) is not satisfied.
.04 Amended BBA partnership
returns. The filing and furnishing option
provided by section 7 of this revenue
procedure applies to BBA partnerships
described in section 7.03 of this revenue procedure for the taxable years
described in section 7.04 of this revenue procedure. This revenue procedure
exercises § 6031(b) authority to allow
a BBA partnership to file an amended
partnership return and issue amended
Schedules K-1 under the circumstances
described in section 7 of this revenue
procedure. A non-BBA partnership that
is required or previously chose to file
Form 1065 must file an amended Form
1065 and issue amended Schedules K-1
to each of its partners.
SECTION 4. WITHDRAWAL OF A
§ 163(j)(7) ELECTION
.01 Time and manner for withdrawing
a § 163(j)(7) election.
(1) In general. A taxpayer within the
scope of section 3.01 of this revenue
procedure may withdraw its § 163(j)(7)
election for a 2022, 2023, or 2024 taxable
year by filing, by the due date described in
section 4.01(3) of this revenue procedure,
an amended Federal income tax return,
amended Form 1065, or AAR, as applicable, for the taxable year for which the
election was initially made, and attaching the election withdrawal statement
described in section 4.01(2) of this revenue procedure.
(2) Procedure. The taxpayer’s amended
Federal income tax return, amended Form
1065, or AAR must clearly indicate that it
is filed pursuant to this revenue procedure.
(a) Electing taxpayers. A taxpayer that
is withdrawing an election under § 163(j)
or making a late § 168(k)(7) election must
write “FILED PURSUANT TO REV.
PROC. 2026-17” at the top of the amended
Federal income tax return, amended Form
1065, or AAR and attach a statement that:
April 6, 2026
(i) Is titled “Revenue Procedure 202617 Section 163(j)(7) Election Withdrawal” or, for taxpayers that are both
withdrawing a § 163(j)(7) election and
making a late election under § 168(k)
(7) on the same return, amended Form
1065, or AAR, is titled “Revenue Procedure 2026-17 Section 163(j)(7) Election
Withdrawal and Late Section 168(k)(7)
Election”;
(ii) Includes the electing taxpayer’s
name, address, and taxpayer identification
number; and
(iii) Includes a statement that, pursuant to Rev. Proc. 2026-17, the electing taxpayer is withdrawing its election
under §§ 163(j)(7)(B), 163(j)(7)(C), or
1.163(j)-1(b)(15)(iii), as applicable and,
if applicable, making a late election under
§ 168(k)(7) on the same return, amended
1065, or AAR.
(b) Affected taxpayers. A taxpayer that
receives an amended Schedule K-1 as a
result of an amended Federal income tax
return or amended Form 1065 filed pursuant to this revenue procedure should
similarly file an amended Federal income
tax return, amended Form 1065, or AAR,
write “FILED PURSUANT TO REV.
PROC. 2026-17” at the top of the amended
Federal income tax return, amended Form
1065, or AAR, and attach a statement that
notes that the affected taxpayer is filing as
a result of receiving an amended Schedule
K-1 from an electing taxpayer that filed an
amended Federal income tax return or an
amended Form 1065 in accordance with
Rev. Proc. 2026-17.
(3) Due date for withdrawing election
on an amended return, amended Form
1065, or AAR.
(a) In general. The amended Federal income tax return or amended Form
1065, as applicable, described in sections 4.01(1) and 4.01(2) of this revenue
procedure must be filed on or before the
earlier of (i) October 15, 2026, or (ii) the
end of the applicable period of limitations
on assessment for the taxable year for
which the amended return is being filed.
A partnership filing an amended Form
1065 must also furnish any corresponding Schedules K-1 by the applicable date
in the previous sentence. In the case of a
BBA partnership filing an AAR, the AAR
described in sections 4.01(1) and 4.01(2)
of this revenue procedure must be filed
808
on or before the earlier of (i) October 15,
2026, and (ii) the last day of the § 6227(c)
period during which the partnership may
file an AAR for the taxable year for which
the election was made.
(i) Taxpayers should be aware that,
with regard to withdrawing a § 163(j)(7)
election, neither § 6501, which governs
the statute of limitations for assessment
and collection, nor § 6511, which governs the statute of limitations for claims
for credit or refund, were amended by
the OBBBA. Section 6501 generally provides that any tax imposed under the Code
shall be assessed within three years after
the return was filed, whether or not the
return was timely filed. Generally, under
§ 6501(b), a return of income tax under
chapter 1 of the Code that is filed before
the due date of the return is deemed filed
on the due date.
(ii) Section 6511 generally provides
that the period of limitations for credit or
refund expires three years from the time
the return was filed or two years from the
time the tax was paid, whichever period
expires later. Under § 6513(a), for purposes of § 6511, any return filed before
the last day prescribed for filing thereof
is considered filed on such last day. Thus,
a claim for credit or refund arising from
a withdrawal of a § 163(j)(7) election
under this section 4 made on an amended
return will be considered timely only if it
is filed on or before the due date for filing
a claim for refund for such taxable year
under § 6511 or § 301.6511(a)-1(a)(1)
(the date that is three years from the time
the return was filed for the taxable year or
within 2 years from the time the tax was
paid, whichever of such periods expires
the later).
(b) Example 1. Taxpayer, a C corporation, timely
filed a Federal income tax return for its taxable year
beginning January 1, 2022, and ending December
31, 2022, on March 1, 2023. Under section 4.01(2)
(a) of this revenue procedure, and consistent with
§ 6501(a) and (b), the taxpayer’s due date for filing
an amended return to withdraw a § 163(j)(7) election under this section 4, for the taxable year ending
December 31, 2022, is April 15, 2026.
(c) Example 2. Taxpayer, a C corporation, timely
filed (including extensions) a Federal income tax
return for its taxable year beginning January 1, 2022,
and ending December 31, 2022, on May 15, 2023.
Under section 4.01(2) of this revenue procedure, and
consistent with § 6501(a), the taxpayer’s due date
for filing an amended return to withdraw a § 163(j)
(7) election under this section 4, for the taxable year
ending December 31, 2022, is May 15, 2026.
Bulletin No. 2026–15
(d) Example 3. Taxpayer, a C corporation, timely
filed (including extensions) a Federal income tax
return for its taxable year beginning February 1,
2022, and ending January 31, 2023, on October 31,
2023. Under section 4.01(2) of this revenue procedure, and consistent with § 6501(a), the taxpayer’s
due date for filing an amended return to withdraw a
§ 163(j)(7) election for the taxable year ending January 31, 2023, is October 15, 2026.
(4) Relevant adjustments. For the withdrawn § 163(j)(7) election to be effective, the amended Federal income tax
return, amended Form 1065, or AAR, as
applicable, must include the adjustments
to taxable income due to the withdrawn
§ 163(j)(7) election and any collateral
adjustments to taxable income or to tax
liability, including modifications to any
adjustments under § 481. An example of
such collateral adjustments is the amount
of depreciation allowed or allowable in
the applicable taxable year for the property to which the withdrawn § 163(j)(7)
election applies.
(5) Affected succeeding taxable years.
A taxpayer also must file amended Federal
income tax returns, amended Forms 1065,
or AARs, as applicable, for any affected
succeeding taxable years to reflect any
adjustments to taxable income due to the
withdrawn § 163(j)(7) election and any
collateral adjustments to taxable income
or to tax liability, including modifications to any adjustments under § 481. An
example of such collateral adjustments
is the amount of depreciation allowed or
allowable in the applicable taxable year
for the property to which the withdrawn
§ 163(j)(7) election applies. A copy of the
election withdrawal statement described
in sections 4.01(1) and 4.01(2) of this
revenue procedure must be attached to
any amended Federal income tax return,
amended Form 1065, or AAR filed for any
affected succeeding taxable years under
this section 4.01(5). The amended Federal
income tax return or amended Form 1065,
as applicable, for an affected succeeding
taxable year must be filed on or before the
earlier of (i) October 15, 2026, and (ii) the
end of the applicable period of limitations
on assessment for the taxable year for
which the amended return is being filed.
A partnership filing an amended Form
1065 must also furnish any corresponding Schedules K-1 by the applicable date
in the previous sentence. In the case of a
BBA partnership filing an AAR, the AAR
Bulletin No. 2026–15
for an affected succeeding taxable year
must be filed on or before the earlier of
(i) October 15, 2026, and (ii) the last day
of the § 6227(c) period during which the
partnership may file an AAR for the taxable year in which the election was made.
.02 Effect of withdrawing a § 163(j)
(7) election. A taxpayer within the scope
of section 3.01 of this revenue procedure
will be treated as if the § 163(j)(7) election
had never been made if the taxpayer withdraws the election as provided in this section 4. If the taxpayer is a partnership, the
capital accounts of the partnership will not
be maintained in accordance with § 1.7041(b)(2)(iv) unless the effect of the withdrawal is reflected in the capital accounts
of its partners.
.03 Depreciation and basis. A taxpayer that is withdrawing a § 163(j)(7)
election must determine its depreciation
deduction for the property that is affected
by the withdrawn election in accordance
with § 168, and include any change in the
amount of such depreciation deduction
due to the withdrawal of the § 163(j)(7)
election as part of the relevant adjustments described in section 4.01(2) of this
revenue procedure, on its amended Federal income tax return, amended Form
1065, or AAR, as applicable. Additionally, the basis of the property affected by
the withdrawn election must be adjusted
to take into account any change in the
amount of such depreciation due to the
withdrawal of the § 163(j)(7) election
and, if applicable, a late § 168(k)(7) election made under section 5 of this revenue
procedure.
.04 If taxpayer is currently under
examination. If a taxpayer is under examination for the 2022, 2023, or 2024 taxable year, the taxpayer must provide a
copy of any amended Federal income tax
return, amended Form 1065, or AAR filed
under sections 4.01(1) or 4.01(5) of this
revenue procedure to the revenue agent
coordinating the taxpayer’s examination
no later than the date the taxpayer files the
amended return, amended Form 1065, or
AAR.
SECTION 5. LATE § 168(k)(7)
ELECTION
.01 Time and manner of making a late
§ 168(k)(7) election.
809
(1) In general. A taxpayer within the
scope of section 3.02 of this revenue procedure may make a late § 168(k)(7) election on the same amended Federal income
tax return, amended Form 1065, or AAR
filed under section 4.01(1) or (5) of this
revenue procedure. The late § 168(k)(7)
election is made in the manner provided
in § 1.168(k)-2(f)(1)(iii)(B). See section
4.01(2) of this revenue procedure for a
description of the statement required to be
attached to an amended return, amended
Form 1065, or AAR that contains a late
§ 168(k)(7) election, and the recommendation for affected taxpayers. An amended
Federal income tax return, amended Form
1065, or AAR filed pursuant to this section 5.01(1) must be filed by the same due
dates described in section 4.01(3) of this
revenue procedure.
(2) Due Date. The due date for the
amended return, amended Form 1065, or
AAR that contains a late § 168(k)(7) election is the same as in section 4.01(3) of
this revenue procedure.
(3) Relevant adjustments. The amended
return, amended Form 1065, or AAR containing a late § 168(k)(7) election must
include any adjustments to taxable income
for the late § 168(k)(7) election and any
collateral adjustments to taxable income
or to tax liability.
(4) Affected succeeding taxable years.
A taxpayer making a late § 168(k)(7) election for a taxable year must file an amended
Federal income tax return, amended Form
1065, or AAR, as applicable, to reflect any
collateral adjustments to taxable income
or to tax liability for any affected succeeding taxable years. An example of such
collateral adjustment is the amount of
depreciation allowed or allowable in the
succeeding taxable years after the taxable
year in which the property is placed in
service. The taxpayer should indicate in a
statement attached to the amended Federal
income tax return, amended Form 1065, or
AAR that it is filing such amended return
or AAR under section 5.02 of Rev. Proc.
2026-17. An amended Federal income tax
return, amended Form 1065, or AAR filed
pursuant to this section 5.01(4) must be
filed by the same due dates described in
section 4.01(5) of this revenue procedure.
.02 If taxpayer is currently under
examination. If a taxpayer is under examination for the 2022, 2023, or 2024 tax-
April 6, 2026
able year, the taxpayer must provide a
copy of any amended Federal income tax
return, amended Form 1065, or AAR filed
under sections 5.01(1) or 5.01(4) of this
revenue procedure to the revenue agent
coordinating the taxpayer’s examination
no later than the date the taxpayer files the
amended return, amended Form 1065, or
AAR.
SECTION 6. CFC GROUP ELECTION
A taxpayer that is a designated U.S.
person may revoke or make a CFC group
election without regard to the 60-month
limitation of § 1.163(j)-7(e)(5)(ii) for the
first specified period of a specified group
beginning after December 31, 2024. A
taxpayer that chooses to revoke the election or make a new election under this
section 6 must follow all procedures specified in § 1.163(j)-7(e)(5) other than the
60-month limitation of § 1.163(j)-7(e)(5)
(ii). In addition, the 60-month limitation
applies to subsequent specified periods.
Thus, for example, if a CFC group election is revoked (or made) under this section 6 for a specified period ending on
December 31, 2025, a new CFC group
election cannot be made (or revoked) with
respect to any specified period beginning
before December 31, 2030.
SECTION 7. OPTION PROVIDED TO
ELIGIBLE BBA PARTNERSHIPS FOR
THE 2022, 2023 AND 2024 TAXABLE
YEARS
.01 Scope. The filing and furnishing
option provided by this section 7 applies to
BBA partnerships described in section 7.03
of this revenue procedure (eligible BBA
partnerships) for the taxable years described
in section 7.04 of this revenue procedure.
.02 Option to file amended Form 1065.
Eligible BBA partnerships may implement this revenue procedure by filing an
amended partnership return and furnishing
corresponding Schedules K-1 instead of filing an AAR. The amended Form 1065 may
take into account tax changes provided by
this revenue procedure as well as any other
tax attributes to which the partnership is
entitled by law. This revenue procedure
allows eligible BBA partnerships the option
to file an amended Form 1065 instead of an
AAR; it does not prevent an eligible BBA
April 6, 2026
partnership from filing an AAR to obtain
the benefits of this revenue procedure or
any other tax benefits to which the partnership is entitled. An eligible BBA partnership that files an amended Form 1065
pursuant to this revenue procedure remains
subject to the centralized partnership audit
procedures enacted by the BBA.
.03 Eligible BBA partnerships. The filing and furnishing option provided in this
section 7 is available only to BBA partnerships that filed Forms 1065 and furnished
Schedules K-1 for the partnership taxable
years beginning in 2022, 2023, or 2024
prior to the issuance of this revenue procedure. A BBA partnership that receives
an amended Schedule K-1 from another
partnership that filed an amended Form
1065 pursuant to this revenue procedure
may also file an amended Form 1065 to
take into account the adjustments in the
amended Schedule K-1 as long as it also
meets the requirements of this revenue
procedure. For purposes of § 6222, the
amended Form 1065 replaces any prior
return (including any AAR filed by the
partnership) for the taxable year for purposes of determining the partnership’s
treatment of partnership-related items. See
section 7.05(3) of this revenue procedure
for a special rule regarding partnerships
that have previously filed AARs for an
affected taxable year.
.04 Eligible taxable years. The filing
and furnishing option provided in this revenue procedure applies only to partnership
taxable years that began in 2022, 2023, or
2024.
.05 Procedure.
(1) Filing requirements. To take advantage of the option to file an amended Form
1065 provided by this section 7, an eligible BBA partnership must, in addition to
meeting the other applicable requirements
set forth in this revenue procedure, file a
Form 1065 (with the “Amended Return”
box checked) and furnish corresponding amended Schedules K‑1. The eligible
BBA partnership should follow the nonBBA partnership instructions for filing an
amended Form 1065. The amended Form
1065 filed pursuant to this section 7 must
be filed, and the corresponding Schedules
K-1 must be furnished, by the deadlines set
forth in section 4.01(3) of this revenue procedure, and the rules applicable to AARs,
including the § 6227(c) filing period, do
810
not apply to an amended Form 1065 filed
under this section 7. As set forth in section
4.01(2) of this revenue procedure, the eligible BBA partnership must clearly indicate
the application of this revenue procedure on
the amended Form 1065 and write “FILED
PURSUANT TO REV. PROC. 2026-17”
at the top of the amended Form 1065 and
attach a statement with each Schedule K-1
sent to its partners with the same notation.
The eligible BBA partnership may file electronically or by mail but filing electronically will allow for faster processing of the
amended Form 1065.
(2) Special rule for eligible BBA partnerships whose returns are under examination. If an eligible BBA partnership is
currently under examination for a taxable
year beginning in 2022, 2023, or 2024 and
wishes to take advantage of the option
to file an amended Form 1065 provided
by this section 7, the partnership may do
so only if the partnership sends notice to
the revenue agent coordinating the partnership’s examination in writing that the
partnership seeks to use the amended
Form 1065 option described in this revenue procedure prior to or contemporaneously with filing the amended Form 1065
as described in this section 7. The partnership must also provide the revenue agent
with a copy of the amended Form 1065
upon filing.
(3) Special rule for eligible BBA partnerships that have previously filed an
AAR. If an eligible BBA partnership has
previously filed an AAR and wishes to file
an amended Form 1065 pursuant to this
revenue procedure for the same taxable
year, the partnership should use the items
as adjusted in the AAR, where applicable,
in lieu of any reporting from the originally
filed partnership return.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective
March 18, 2026.
SECTION 9. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Elizabeth A. Bukis of the
Office of Associate Chief Counsel (Income
Tax & Accounting) and Caleb W. Trimm,
Alexander D. Valenzuela, and Raphael J.
Bulletin No. 2026–15
Cohen of the Office of Associate Chief
Counsel (International). For further information regarding this revenue procedure
relating to § 163(j), contact Ms. Bukis at
(202) 317-7011 (not a toll-free number);
Bulletin No. 2026–15
for further information regarding this revenue procedure relating to depreciation,
please contact the Office of the Associate
Chief Counsel (Income Tax & Accounting), Branch 7 at (202) 317-7005 (not a
811
toll-free number); for further information
regarding this revenue procedure relating
to the CFC group election, contact Mr.
Trimm, Mr. Valenzuela, or Mr. Cohen at
(202) 317-6938 (not a toll-free number).
April 6, 2026
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior published position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confusion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously published ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the substance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations
to show that the previous published rulings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
Bulletin No. 2026–15
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.
April 6, 2026
Numerical Finding List1
Bulletin 2026–15
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
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
Revenue Procedures:—Continued
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
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
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
Proposed Regulations:
REG-101952-24, 2026-03 I.R.B. 345
REG-110519-25, 2026-03 I.R.B. 353
REG-132251-11; REG-134219-08,
2026-03 I.R.B. 358
REG-103430-24, 2026-05 I.R.B. 447
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
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
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
April 6, 2026
ii
Bulletin No. 2026–15
Finding List of Current Actions on
Previously Published Items1
Bulletin 2026–15
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. 2026–15
iii
April 6, 2026
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
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