Bulletin No. 2026–15

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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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