Bulletin No. 2026–29
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HIGHLIGHTS
OF THIS ISSUE
Bulletin No. 2026–29
July 13, 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
EXEMPT ORGANIZATIONS
Announcement 2026-11, page 49.
Announcement 2026-12, page 50.
This Announcement advises the public that the Internal Revenue Service is revising the optional standard mileage rates
for substantiating the costs of operating an automobile for
business, medical or moving purposes. These revised rates
are effective beginning July 1, 2026. This Announcement
modifies Notice 2026-10.
ESTATE TAX, GIFT TAX
Rev. Proc. 2026-25, page 45.
This is a revenue procedure that provides a safe harbor for
individual taxpayers who (i) make contributions to Trump
accounts established under § 530A of the Internal Revenue
Code and (ii) satisfy certain specified conditions. If the conditions are satisfied, contributions to Trump accounts will
be treated as completed gifts that are not future interests
in property and to which the annual per-donee gift tax exclusion applies. As a result, taxpayers within the scope of the
revenue procedure will not be required to file gift tax returns
reporting such contributions.
EXCISE TAX
Notice 2026-43, page 42.
This Notice of Determinations adds 2 chemical substances
to the list of taxable substances under § 4672 subject to
the tax imposed by § 4671.
Finding Lists begin on page ii.
Revocation of IRC 501(c)(3) Organizations for failure to
meet the code section requirements. Contributions made to
the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).
INCOME TAX
Notice 2026-41, page 39.
This notice publishes the 2026 calendar-year inflation
adjustment factor for the section 45U zero-emission nuclear
power production credit, as well as the inflation adjustment
factors and corresponding applicable amounts for the section 45V clean hydrogen production credit and the section
45Z clean fuel production credit, respectively. The inflation
adjustment factors (applicable to sections 45U, 45V, and
45Z) and the applicable amounts (in the case of sections
45V and 45Z) are used to determine the amount of the
credit allowable under sections 45U, 45V, and 45Z.
Notice 2026-42, page 41.
This notice publishes the applicable reference price and
credit amount under § 45I of the Internal Revenue Code
for qualified natural gas production from qualified marginal
wells during taxable years beginning in calendar year 2026.
The applicable reference price and credit amount are used
in determining the marginal well production credit under
§ 45I for qualified natural gas production.
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
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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,
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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
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identifying details and information of a confidential nature are
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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
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procedures, the effect of subsequent legislation, regulations,
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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.
July 13, 2026
Bulletin No. 2026–29
Part III
Zero-Emission Nuclear
Power Production Credit
2026 Section 45U Inflation
Adjustment Factor
Credit for Production of
Clean Hydrogen
2026 Section 45V Inflation
Adjustment Factor and
Applicable Amount
Clean Fuel Production Credit
2026 Section 45Z Inflation
Adjustment Factor and
Applicable Amount
Notice 2026-41
SECTION 1. PURPOSE
This notice publishes the inflation adjustment factors and applicable
amounts, as appropriate, for calendar year
2026 for the zero-emission nuclear power
production credit under § 45U of the
Internal Revenue Code (Code) (the § 45U
credit), the credit for production of clean
hydrogen under § 45V of the Code (the
§ 45V credit), and the clean fuel production credit under § 45Z of the Code (the
§ 45Z credit). These inflation adjustment
factors and applicable amounts, as appropriate, are used to determine the corresponding credit amounts under §§ 45U,
45V, and 45Z.
SECTION 2. BACKGROUND
.01 Section 45U.
Section 45U was added to the Code by
section 13105 of Public Law 117-169, 136
Stat. 1818, 1929 (August 16, 2022), commonly known as the Inflation Reduction
Act of 2022 (IRA), to provide an income
tax credit for producing electricity at a
qualified nuclear power facility.
Section 45U(a) provides that, for purposes of § 38, the § 45U credit for any
taxable year is an amount equal to the
amount by which the product of 0.3 cents
Bulletin No. 2026–29
(the amount provided in § 45U(a)(1)(A))
and the kilowatt hours of electricity the
taxpayer produced at a qualified nuclear
power facility and sold to an unrelated
person during the taxable year, exceeds
the reduction amount for that taxable
year.
Section 45U(b)(2) defines the reduction amount as the lesser of: (1) the
amount determined under § 45U(a) before
application of the reduction amount, or
(2) the amount equal to 16 percent of the
excess of, subject to other rules regarding
the treatment of certain receipts, the gross
receipts from any electricity produced by
a qualified nuclear power facility (including any electricity services or products
provided in conjunction with the electricity produced by such facility) and sold to
an unrelated person during the taxable
year, over the amount equal to the product of 2.5 cents (the amount provided in
§ 45U(b)(2)(A)(ii)(II)(aa)), multiplied
by the kilowatt hours of electricity determined in § 45U(a).
Section 45U(c)(1) provides that the
0.3 cent amount in § 45U(a)(1)(A) and
the 2.5 cent amount in § 45U(b)(2)(A)(ii)
(II)(aa) are each adjusted by multiplying
such amounts by the inflation adjustment
factor (as determined under § 45(e)(2), by
substituting “2023” for “1992” in § 45(e)
(2)(B)) for the calendar year in which the
sale of electricity (as defined in § 45U(b)
(3)) occurred. If the 0.3 cent and 2.5 cent
amounts, as increased under § 45U(c)
(1), are not multiples of 0.05 cent and 0.1
cent, respectively, then such amounts are
rounded to the nearest multiples of 0.05
cent and 0.1 cent, respectively.
.02 Section 45V.
Section 45V was added to the Code by
IRA section 13204, 136 Stat. at 1935, to
provide an income tax credit for producing qualified clean hydrogen.
Section 45V(a) provides that, for purposes of § 38, the § 45V credit for any
taxable year is an amount equal to the
product of (1) the kilograms of qualified
clean hydrogen produced by the taxpayer
during such taxable year at a qualified
clean hydrogen production facility during
the 10-year period beginning on the date
such facility was originally placed in ser-
39
vice, and (2) the applicable amount as
determined under § 45V(b) with respect
to such hydrogen.
Section 45V(b)(1) provides that, for
purposes of § 45V(a)(2), the applicable
amount is an amount equal to the applicable percentage of $0.60. If the amount so
determined is not a multiple of 0.1 cent,
then such amount is rounded to the nearest
multiple of 0.1 cent.
Section 45V(b)(2) provides that, for
purposes of § 45V(b)(1), the applicable
percentage is determined based on the
lifecycle greenhouse gas emissions (lifecycle GHG emissions) rate of the process used to produce any qualified clean
hydrogen as follows: (i) if the lifecycle
GHG emissions rate is not greater than
4 kilograms of carbon dioxide equivalent
(CO2e) per kilogram of hydrogen, and
not less than 2.5 kilograms of CO2e per
kilogram of hydrogen, then the applicable percentage is 20 percent; (ii) if the
lifecycle GHG emissions rate is less than
2.5 kilograms of CO2e per kilogram of
hydrogen, and not less than 1.5 kilograms
of CO2e per kilogram of hydrogen, then
the applicable percentage is 25 percent;
(iii) if the lifecycle GHG emissions rate
is less than 1.5 kilograms of CO2e per
kilogram of hydrogen, and not less than
0.45 kilograms of CO2e per kilogram of
hydrogen, then the applicable percentage is 33.4 percent; and (iv) if the lifecycle GHG emissions rate is less than
0.45 kilograms of CO2e per kilogram of
hydrogen, then the applicable percentage
is 100 percent.
Section 45V(b)(3) provides that the
$0.60 amount in § 45V(b)(1) is adjusted by
multiplying such amount by the inflation
adjustment factor (as determined under
§ 45(e)(2), by substituting “2022” for
“1992” in § 45(e)(2)(B)) for the calendar
year in which the qualified clean hydrogen
is produced. If any amount as increased
under § 45V(b)(3) is not a multiple of 0.1
cent, then such amount is rounded to the
nearest multiple of 0.1 cent.
.03 Section 45Z.
Section 45Z was added to the Code by
IRA section 13704, 136 Stat. at 1997, to
provide an income tax credit for producing clean transportation fuel.
July 13, 2026
Section 45Z(a)(1) provides that, for
purposes of § 38, the § 45Z credit for any
taxable year is an amount equal to the
product of (1) the applicable amount per
gallon (or gallon equivalent) with respect
to any transportation fuel which is produced by the taxpayer at a qualified facility and sold by the taxpayer in a specific
manner during the taxable year, and (2)
the emissions factor for such fuel as determined under § 45Z(b).
As enacted by the IRA, § 45Z(a)(2)
and (3) provided the applicable amounts
for transportation fuels. Specifically, for
transportation fuel that was not a sustainable aviation fuel (non-SAF transportation fuel), the applicable amount was
20 cents under § 45Z(a)(2)(A), or $1.00
under § 45Z(a)(2)(B). For transportation
fuel that was a sustainable aviation fuel
(SAF transportation fuel), the applicable
amount was 35 cents under § 45Z(a)(3)
(A)(i), or $1.75 under § 45Z(a)(3)(A)(ii).
Section 45Z refers to the lower amount
for a fuel as the base amount and to the
higher amount for a fuel as the alternative
amount. A taxpayer uses the alternative
amount if it produces transportation fuel
at a qualified facility that satisfies certain prevailing wage and apprenticeship
requirements.
Section 70521(g)(2) of Public Law
119-21, 139 Stat. 72, 278 (July 4, 2025),
commonly known as the One, Big, Beautiful Bill Act, amended § 45Z by eliminating the higher applicable amounts for
SAF transportation fuel. This amendment
applies to fuel produced after December
31, 2025. Thus, for all transportation fuel
produced after December 31, 2025, the
applicable amount is either 20 cents or
$1.00 as provided in § 45Z(a)(2). However, for transportation fuel produced
between January 1, 2025, and December 31, 2025, the applicable amounts are
those as enacted under the IRA and differ for SAF and non-SAF transportation
fuel.
Section 45Z(c)(1) provides that, for
calendar years beginning after 2024, the
applicable amount must be adjusted by
multiplying such amount by the inflation
adjustment factor for the calendar year
in which the sale of the transportation
fuel occurs. Any amount adjusted under
§ 45Z(c)(1) must be rounded to the nearest
cent. Section 45Z(c)(2) provides that the
July 13, 2026
inflation adjustment factor for the § 45Z
credit is the inflation adjustment factor
determined and published by the Secretary
of the Treasury or his delegate pursuant to
§ 45Y(c), determined by substituting “calendar year 2022” for “calendar year 1992”
in § 45Y(c)(3).
.04 Sections 45(e)(2)(B) and 45Y(c)(3).
Sections 45(e)(2)(B) and 45Y(c)(3)
define the term inflation adjustment factor as, with respect to a calendar year, a
fraction, the numerator of which is the
GDP implicit price deflator for the preceding calendar year and the denominator of which is the GDP implicit price
deflator for the calendar year 1992.
Under both statutes, the term GDP
implicit price deflator means the most
recent revision of the implicit price
deflator for the gross domestic product as computed and published by the
Department of Commerce before March
15 of the calendar year.
SECTION 3. INFLATION
ADJUSTMENT FACTORS AND
APPLICABLE AMOUNTS
.01 2026 Section 45U Inflation Adjustment Factor.
For purposes of § 45U(c)(1), for sales
of electricity occurring in calendar year
2026, the inflation adjustment factor is
a fraction, the numerator of which is
the GDP implicit price deflator for 2025
(128.986) and the denominator of which
is the GDP implicit price deflator for 2023
(122.39), which yields an inflation adjustment factor of 1.0539.
For sales of electricity occurring in
calendar year 2026, the amount provided
in § 45U(a)(1)(A) is 0.3 cents (0.3 cents
(or $0.003) x 1.0539, then rounded to the
nearest multiple of 0.05 cent). The amount
provided in § 45U(b)(2)(A)(ii)(II)(aa) is
2.6 cents (2.5 cents (or $0.025) x 1.0539,
then rounded to the nearest multiple of 0.1
cent).
.02 2026 Section 45V Inflation Adjustment Factor and Applicable Amount.
For purposes of § 45V(b)(3), for qualified clean hydrogen produced in calendar
year 2026, the inflation adjustment factor
is a fraction, the numerator of which is
the GDP implicit price deflator for 2025
(128.986) and the denominator of which
is the GDP implicit price deflator for
40
2022 (118.023), which yields an inflation
adjustment factor of 1.0929.
For qualified clean hydrogen produced
in calendar year 2026, the applicable
amount determined under § 45V(b)(1) is
the product of $0.656 ($0.60 x 1.0929,
then rounded to the nearest multiple of 0.1
cent) and the applicable percentage, which
depends on the lifecycle GHG emissions
rate of the qualified clean hydrogen production process. Thus, for qualified clean
hydrogen produced through a process that
results in a lifecycle GHG emissions rate
of:
(i) not greater than 4 kilograms of
CO2e per kilogram of hydrogen, and not
less than 2.5 kilograms of CO2e per kilogram of hydrogen, the applicable amount
is $0.131;
(ii) less than 2.5 kilograms of CO2e
per kilogram of hydrogen, and not less
than 1.5 kilograms of CO2e per kilogram
of hydrogen, the applicable amount is
$0.164;
(iii) less than 1.5 kilograms of CO2e
per kilogram of hydrogen, and not less
than 0.45 kilograms of CO2e per kilogram
of hydrogen, the applicable amount is
$0.219; and
(iv) less than 0.45 kilograms of CO2e
per kilogram of hydrogen, the applicable
amount is $0.656.
.03 2026 Section 45Z Inflation Adjustment Factor and Applicable Amount.
For purposes of § 45Z(c), for transportation fuel sold in calendar year 2026,
the inflation adjustment factor is a fraction, the numerator of which is the GDP
implicit price deflator for 2025 (128.986)
and the denominator of which is the GDP
implicit price deflator for 2022 (118.023),
which yields an inflation adjustment factor of 1.0929.
For all transportation fuel produced
and sold in calendar year 2026, and for
non-SAF transportation fuel produced in
calendar year 2025 and sold in calendar
year 2026:
(i) The base amount is 22 cents (20
cents x 1.0929, then rounded to the nearest
cent) under § 45Z(a)(2)(A).
(ii) The alternative amount is $1.09
($1.00 x 1.0929, then rounded to the nearest cent) under § 45Z(a)(2)(B).
For SAF transportation fuel produced
in calendar year 2025 and sold in calendar
year 2026:
Bulletin No. 2026–29
(i) The base amount is 38 cents (35
cents x 1.0929, then rounded to the nearest
cent) under § 45Z(a)(3)(A)(i) as enacted
by IRA § 13704.
(ii) The alternative amount is $1.91
($1.75 x 1.0929, then rounded to the
nearest cent) under § 45Z(a)(3)(A)(ii) as
enacted by IRA § 13704.
SECTION 4. DRAFTING
INFORMATION
The principal authors of this notice are
Whitney Brady, Glenn Kats, and Andrew
Clark of the Office of Associate Chief
Counsel (Energy, Credits, and Excise
Tax). For further information regarding
this notice contact Whitney Brady at (202)
317-6325, Glenn Kats at (202) 317-3995,
or Andrew Clark at (202) 317-6855 (not
toll-free numbers).
Reference Price for Section
45I Credit for Production of
Natural Gas from Marginal
Wells During Taxable Years
Beginning in Calendar Year
2026
Notice 2026-42
SECTION 1. PURPOSE
This notice provides the applicable
reference price for qualified natural gas
production from qualified marginal wells
during taxable years beginning in calendar
year 2026 for the purpose of determining
the marginal well production credit (MWC)
under § 45I of the Internal Revenue Code.
The applicable reference price for taxable
years beginning in calendar year 2026 is
$2.20 per 1,000 cubic feet (Mcf).
This notice also provides the credit
amount used for the purpose of determining the MWC for taxable years beginning in calendar year 2026. The credit
amount is determined using the 2026
inflation adjustment factor of 1.6295 and
the applicable reference price of $2.20 per
Mcf. The credit amount for taxable years
beginning in calendar year 2026 is $0.81
per Mcf.
Bulletin No. 2026–29
SECTION 2. BACKGROUND
Section 45I(a), as it relates to qualified natural gas production, provides that,
for purposes of § 38, the MWC for any
taxable year is an amount equal to the
product of (1) the credit amount and (2)
the qualified natural gas production that is
attributable to the taxpayer.
Section 45I(c)(1) provides that “qualified natural gas production” means
domestic natural gas produced from a
qualified marginal well. Section 45I(c)
(3)(A) provides that a qualified marginal
well is a domestic well (i) the production from which during the taxable year
is treated as marginal production under
§ 613A(c)(6), or (ii) which, during the
taxable year (I) has average production
of not more than 25 barrel-of-oil equivalents per day, and (II) produces water at a
rate not less than 95 percent of total well
effluent.
Section 613A(c)(6)(D) and (E) provide that “marginal production” means
domestic natural gas produced during
any taxable year from a property which is
a stripper well property for the calendar
year in which the taxable year begins. A
“stripper well property” is, with respect
to any calendar year, any property producing not more than 15 barrel equivalents per day, determined by dividing
the average daily production of domestic
crude oil and domestic natural gas from
producing wells on the property for such
calendar year by the number of such
wells.
Section 45I(c)(2)(A) provides that
generally only the first 1,095 barrels or
barrel-of-oil equivalents (as defined in §
45K(d)(5)) produced during the taxable
year qualify for the MWC. This limitation is proportionately reduced in the
case of a short taxable year or in the case
of a well that is not capable of production
each day of a taxable year. See § 45I(c)
(2)(B). The number of wells on which a
taxpayer may claim the MWC is not limited.
Section 45I(d)(2) provides that to claim
the credit a taxpayer must hold an operating interest in the qualified marginal well
producing the natural gas to which the
credit relates. Under § 45I(d)(1) if a well
is owned by more than one owner and the
natural gas production exceeds the lim-
41
itation under § 45I(c)(2), the qualifying
natural gas production attributable to the
taxpayer is determined on the basis of the
ratio which the taxpayer’s revenue interest
in the production bears to the aggregate
of the revenue interests of all operating
interest owners in the production. Finally,
§ 45I(d)(3) provides that the MWC is not
allowable if the taxpayer is also eligible to
claim the § 45K nonconventional sources
credit for the taxable year, unless the taxpayer elects not to claim the credit under §
45K for the well.
For purposes of § 45I(a)(1), the credit
amount is 50 cents (adjusted for inflation)
per Mcf of qualified natural gas production
(tentative credit amount). See § 45I(b)(1)
(B) and (b)(2)(B).
Section 45I(b)(2)(A) and (B) provide
that the tentative credit amount (adjusted
for inflation) is reduced (but not below
zero) to the extent that the applicable
reference price exceeds $1.67 (adjusted
for inflation). More specifically, § 45I(b)
(2)(A) provides that the tentative credit
amount (adjusted for inflation) is reduced
by an amount which bears the same ratio
to the tentative credit amount (adjusted
for inflation) as the excess (if any) of
the applicable reference price over $1.67
(adjusted for inflation), bears to $0.33
(adjusted for inflation). As a result, the
MWC is not available if the applicable
reference price for qualified natural gas
production is $2.00 (adjusted for inflation)
or more.
Section 45I(b)(2)(A) also provides that
the applicable reference price for a taxable
year is the reference price for the calendar
year preceding the calendar year in which
the taxable year begins. Section 45I(b)(2)
(C)(ii) provides that the term “reference
price” means, with respect to any calendar
year, in the case of qualified natural gas
production, the Secretary’s estimate of the
annual average wellhead price per Mcf for
all domestic natural gas.
Section 45I(b)(2)(B) provides that in
the case of any taxable year beginning
in a calendar year after 2005, each of
the dollar amounts contained in § 45I(b)
(2)(A) will be increased to an amount
equal to such dollar amount multiplied
by the inflation adjustment factor for
such calendar year (determined under §
43(b)(3)(B) by substituting “2004” for
“1990”).
July 13, 2026
SECTION 3. INFLATION
ADJUSTMENT FACTOR AND
REFERENCE PRICE
.1 Inflation Adjustment. The inflation
adjustment factor under § 45I(b)(2)(B) for
calendar year 2026 is 1.6295.
.2 Reference Price. The Secretary’s
estimate of the calendar year 2025 annual
average wellhead price per Mcf for all
domestic natural gas under § 45I(b)(2)
(C)(ii) was calculated by applying the
Producer Price Index commodity index
for “Natural Gas from the Wellhead”
(WPU053101051)1 published by the
Bureau of Labor Statistics (BLS) as part
of its Producer Price Index program, to
the 2024 annual average wellhead price
($1.64) published in Notice 2025-34,
2025-27 I.R.B. 6. The annual Producer
Price Index commodity index for natural
gas published by the BLS was 50.869 in
2024 and 68.301 in 2025, which implies
a ratio of 2025 to 2024 average wellhead
prices of 1.343 (68.301/50.869). Therefore, the Secretary’s estimate of the calendar year 2025 annual average wellhead
price per Mcf for all domestic natural gas
is $2.20 per Mcf (1.343 × $1.64 per Mcf).
For years after 2025, the Secretary
intends to continue calculating the reference price by application of the Producer Price Index commodity index
for “Natural Gas from the Wellhead”
(WPU053101051) published by the BLS
to the previous year’s reference price.
SECTION 4. CALCULATION OF
CREDIT AMOUNT
Under § 45I(b)(1)(B) and (2)(B), the
tentative credit amount used to calculate
the MWC for taxable years beginning
in calendar year 2026 is $0.81 per Mcf
($0.50 × 1.6295 inflation adjustment factor).
Pursuant to § 45I(b)(2)(A), the tentative credit amount ($0.81) is reduced (but
not below zero) by an amount (the Reduction Amount) which bears the same ratio
to such amount as (i) the excess (if any) of
the applicable reference price ($2.20) over
$2.72 ($1.67 × 1.6295 inflation adjustment factor), bears to (ii) $0.54 ($0.33 ×
1
1.6295 inflation adjustment factor). The
Reduction Amount (as adjusted for inflation) is computed as follows:
Reduction Amount $2.20 – $2.72
=
$0.81
$0.54
The Reduction Amount is -$0.78
(($2.20 - $2.72) ÷ $0.54 × $0.81), which
is less than zero, therefore, the tentative
credit amount ($0.81) is not reduced.
the taxable substances added to the list is
October 1, 2026. The effective date for
purposes of refund claims under section
4662(e) of the Code for the taxable substances added to the list is April 1, 2023.
FOR FURTHER INFORMATION
CONTACT: Julia Barlow at (202) 3176855 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
SECTION 5. EFFECTIVE DATE
Background
This notice is effective for qualified
natural gas production during taxable
years beginning in calendar year 2026.
Section 4671(a) of the Code imposes
an excise tax on the sale or use of a taxable
substance by the importer thereof (section
4671 tax). Section 4672(a)(1) of the Code
defines the term taxable substance as any
substance which, at the time of sale or use
by the importer, is listed as a taxable substance by the Secretary of the Treasury or
the Secretary’s delegate (Secretary) on the
list of taxable substances under section
4672(a) (List).
Under section 4672(a)(2), an importer
or exporter of any substance may request
that the Secretary determine whether such
substance should be added to the List as
a taxable substance or should be removed
from the List. Under section 4672(a)(2)
(B) and (a)(4) and (b)(2), the Secretary
is required to add a substance to the List
if the Secretary determines that any taxable chemicals that are listed in section
4661(b) of the Code constitute more than
20 percent of the weight, or more than
20 percent of the value, of the materials
used to produce such substance, which
determination is required under section
4672(a)(2)(B) and (a)(4) to be made based
on the predominant method of production
(weight or value test). Section 4672(a)(4)
authorizes the Secretary to remove a substance from the List only if such substance
meets neither the weight nor the value test
of section 4672(a)(2)(B).
Section 4672(a)(3) includes an initial
list of taxable substances. Section 4 of
Notice 2021-66 (2021-52 I.R.B. 901) provides the list of 101 substances that the
Secretary added to the List before November 15, 2021. On May 31, 2024, the Secretary published a Notice of Determination
SECTION 6. DRAFTING AND
CONTACT INFORMATION
The principal author of this notice
is Alan W. Tilley of the Office of Associate Chief Counsel (Energy, Credits,
and Excise Tax). For further information
regarding this notice, contact Mr. Tilley
on (202) 317-6512 (not a toll-free number).
Superfund Tax on Chemical
Substances; Notice of
Determinations to Add
Substances to List of
Taxable Substances
Notice 2026-43
SUMMARY: This notice of
determinations modifies the list of taxable
substances to include the following two
substances: chloro-isobutene-isoprene
rubber ((C4H8)n-(C5H7.31Cl0.69)m; n=97.75,
m=2.25) and ethylene-propylenedicyclopentadiene rubber ((C2H4)m-(C3H6)n
-(C10H12)o; m=73.18, n=26.53, o=0.29).
EFFECTIVE DATES: The effective date
for purposes of the tax under section 4671
of the Internal Revenue Code (Code) for
https://data.bls.gov/cgi-bin/srgate. The BLS publishes indexes and not actual or average prices.
July 13, 2026
42
Bulletin No. 2026–29
in the Federal Register (89 FR 47238)
adding polyoxymethylene to the List; this
Notice of Determination was also published in the Internal Revenue Bulletin as
Notice 2024-50 (2024-26 I.R.B. 1789).
On August 4, 2025, the Secretary published a Notice of Determinations in the
Federal Register (90 FR 36520) adding
21 substances to the List; this Notice of
Determinations was also published in the
Internal Revenue Bulletin as Notice 202541 (2025-34 I.R.B. 325). On September
17, 2025, the Secretary published a Notice
of Determinations in the Federal Register (90 FR 44881) adding 39 substances
to the List; this Notice of Determinations
was also published in the Internal Revenue Bulletin as Notice 2025-51 (2025-41
I.R.B. 448). Rev. Proc. 2022-26 (202229 I.R.B. 90), as modified by Rev. Proc.
2023-20 (2023-15 I.R.B. 636), provides
the exclusive procedures by which an
importer, exporter, or interested person
may request a determination that a particular substance be added to or removed
from the List.
Section 4671(b)(3) authorizes the Secretary to prescribe a tax rate for taxable
substances in lieu of the tax rate specified
in section 4671(b)(2). The tax rate prescribed by the Secretary for a substance
added to the List is calculated by multiplying the conversion factor for each taxable
chemical used in the production of the
substance by the corresponding tax rate
for that taxable chemical under section
4661(b), and adding those results together.
Conversion factors are determined based
on the predominant method of production of the substance. See sections 8 and
10.04(8) of Rev. Proc. 2022-26. Importers are not required to use the prescribed
tax rate for a taxable substance and may
calculate their own rate under section
4671(b)(1).
Pursuant to Section 4672(a)(4), this
notice of determinations modifies the List
to include the two additional taxable substances listed in the Summary of Determinations section of this notice, as explained
in the Requests to Add Substances to the
List and General Explanation of Determinations sections of this notice. The
determination for each specific substance
added to the List is explained in parts 1
and 2 of the Modifications to the List of
Taxable Substances section of this notice.
Bulletin No. 2026–29
The updated List and prescribed
tax rates for taxable substances will be
included in the instructions to Form 6627,
Environmental Taxes.
Summary of Determinations
On June 26, 2026, the Secretary determined to add the following substances to
the List:
1. Chloro-isobutene-isoprene
rubber
((C4H8)n-(C5H7.31Cl0.69)m;
n=97.75,
m=2.25)
2. Ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n-(C10H12)o;
m=73.18, n=26.53, o=0.29)
Requests to Add Substances to the List
For each of the substances listed in
the Summary of Determinations section of this notice, an importer or an
exporter submitted a petition to the IRS
in accordance with Rev. Proc. 2022-26
requesting a determination under section 4672(a)(2) to add the substance to
the List. For each substance, the petition represented that taxable chemicals
constitute more than 20 percent of the
weight of materials used to produce the
substance, based on the predominant
method of production.
General Explanation of Determinations
After reviewing the petitions for each
of the substances listed in the Summary
of Determinations section of this notice,
the Secretary determined that taxable
chemicals constitute more than 20 percent by weight of the materials used to
produce the substance, based on the predominant method of production. Therefore, both of the substances are added to
the List as required under section 4672(a)
(2) and (4). The Secretary made the determinations to add these substances to the
List in accordance with the requirements
of section 4672(a)(2) and (4), and pursuant to the procedures set forth in Rev.
Proc. 2022-26, as modified by Rev. Proc.
2023-20.
The relevant information for each
taxable substance is provided in the specific determinations included in parts 1
and 2 of the Modifications to the List
of Taxable Substances section of this
43
notice. The tax rate for each taxable
substance, as prescribed by the Secretary, is provided in paragraph (a)(6) of
each specific determination. All scientific information provided in the specific
determinations reflects the information
provided by petitioners as published
in each taxable substance’s respective
Notice of Filing.
Classification numbers proposed by
each petitioner are included in paragraph
(b) of each part, after each specific determination. The classification numbers
provided with respect to a taxable substance are not part of the determination
of whether it is added to the List and
do not impact whether such substance
is a taxable substance. Taxpayers may
not rely on classification numbers for
any purpose under sections 4661, 4662,
4671, and 4672, including (but not limited to) identification of a substance as a
taxable substance on the List. Classification numbers may change over time. The
Department of the Treasury (Treasury
Department) and the IRS do not anticipate updating this document to reflect
any such changes.
For purposes of the section 4671 tax,
all the modifications in parts 1 and 2 of
the Modifications to the List of Taxable
Substances section of this notice are effective on and after October 1, 2026. For
purposes of refund claims under section
4662(e), the modifications are effective
April 1, 2023.
Modifications to the List of Taxable
Substances
1. Determination to Add Chloroisobutene-isoprene Rubber ((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25) to
the List
Arlanxeo USA LLC and Arlanxeo
Canada Inc., importers and exporters of
chloro-isobutene-isoprene rubber ((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25), submitted a petition in accordance with
Rev. Proc. 2022-26 requesting to add
chloro-isobutene-isoprene rubber ((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25) to the
List. According to the petition, the taxable
chemicals butylene, chlorine, and sodium
hydroxide constitute 97.36 percent by
weight of the materials used to produce
July 13, 2026
this substance, based on the predominant
method of production.
(a) Determination. Chloro-isobutene-isoprene
rubber
((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25) is
added to the list of taxable substances
under section 4672(a). Other pertinent
information is as follows:
(1) Predominant method of production:
The predominant method of producing
chloro-isobutene-isoprene rubber involves
reacting a hexane solution of butyl rubber
with elemental chlorine. Butyl rubber is
produced via the cationic copolymerization of butylene with isoprene in the presence of a Friedel-Crafts catalyst at low
temperature, around -100°C.
(2) Stoichiometric material consumption equation:
n C4H8 (butylene) + m C5H8 (isoprene) +
(0.69m) Cl2 (chlorine) + (0.69m) NaOH
(sodium hydroxide) → (C4H8)n
(C5H7.31Cl0.69)m (chloro-isobutene-isoprene
rubber) + (0.69m) NaCl + (0.69m) H2O
(3) Reasons for the determination: The
chloro-isobutene-isoprene rubber ((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25) petition was filed on July 13, 2025. The notice
of filing summarizing the petition and
requesting comments was published in
the Federal Register (90 FR 39468) on
August 15, 2025. The Treasury Department and the IRS received no substantive written comments in response to the
notice of filing. A public hearing was neither requested nor held.
The Secretary followed the process in section 4672(a)(2)(B) in making this determination. A review of the
stoichiometric material consumption
equation and other information in the
petition shows that the taxable chemicals butylene, chlorine, and sodium
hydroxide constitute more than 20 percent by weight of the materials used
in the production of chloro-isobutene-isoprene
rubber
((C4H8)n
-(C5H7.31Cl0.69)m; n=97.75, m=2.25),
based on the predominant method of
production. Therefore, the test in section
4672(a)(2)(B) is satisfied.
(4) Date of determination: June 26,
2026.
(5) Effective dates for addition of
chloro-isobutene-isoprene rubber ((C4H8)n
July 13, 2026
-(C5H7.31Cl0.69)m; n=97.75, m=2.25) to the
List:
(i) Effective date for purposes of the
section 4671 tax (see section 11.01 of Rev.
Proc. 2022-26): October 1, 2026.
(ii) Effective date for purposes of refund
claims under section 4662(e) (see sections
11.02 and 11.03 of Rev. Proc. 2022-26, as
modified by section 3 of Rev. Proc. 202320): April 1, 2023.
(6) Tax rate prescribed by the Secretary: $9.46 per ton. The conversion factors for the taxable chemicals used in the
production of chloro-isobutene-isoprene
rubber ((C4H8)n-(C5H7.31Cl0.69)m; n=97.75,
m=2.25) are 0.96 for butylene, 0.02 for
chlorine, and 0.01 for sodium hydroxide.
The tax rate is calculated by adding the
products of the conversion factor for each
taxable chemical by the tax rate for that
taxable chemical: ((0.96 x $9.74) + (0.02
x $5.40) + (0.01 x $0.56) = $9.46).
(b) Classification numbers.
(1) The Secretary has no basis to object
to the following proposed classification
numbers:
(i) HTSUS number: 4002.39.0000.
(ii) Schedule B number: 4002.39.0000.
(iii) CAS number: 68081-82-3.
(2) The Secretary is unable to confirm the following proposed classification
numbers: Not applicable.
2. Determination to Add Ethylenepropylene-dicyclopentadiene Rubber
((C2H4)m-(C3H6)n-(C10H12)o; m=73.18,
n=26.53, o=0.29) to the List
Arlanxeo USA LLC and Arlanxeo Canada Inc., importers and exporters of ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n-(C10H12)o; m=73.18,
n=26.53, o=0.29), submitted a petition
in accordance with Rev. Proc. 2022-26
requesting to add ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n
-(C10H12)o; m=73.18, n=26.53, o=0.29)
to the List. According to the petition, the
taxable chemicals ethylene and propylene
constitute 98.80 percent by weight of the
materials used to produce this substance,
based on the predominant method of production.
(a) Determination. Ethylene-propylene-dicyclopentadiene rubber ((C2H4)m
-(C3H6)n-(C10H12)o; m=73.18, n=26.53,
o=0.29) is added to the list of taxable sub-
44
stances under section 4672(a). Other pertinent information is as follows:
(1) Predominant method of production:
The predominant method of producing
ethylene-propylene-dicyclopentadiene
rubber is through the catalytic polymerization of ethylene, propylene, and non-conjugated diene monomers in a solution
using various catalysts. Non-conjugated
diene monomers include ethylidene norbornene and dicyclopentadiene. The
non-conjugated diene monomers are produced from cyclopentadiene and butadiene, and cyclopentadiene, respectively.
(2) Stoichiometric material consumption equation:
m C2H4 (ethylene) + n C3H6 (propylene) +
o [2 C5H6 (cyclopentadiene)] → (C2H4)m
(C3H6)n(C10H12)o (ethylene-propylene-dicyclopentadiene rubber)
(3) Reasons for the determination:
The ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n-(C10H12)o;
m=73.18, n=26.53, o=0.29) petition was
filed on July 13, 2025. The notice of filing
summarizing the petition and requesting
comments was published in the Federal
Register (90 FR 39469) on August 15,
2025. The Treasury Department and the
IRS received no written comments in
response to the notice of filing. A public
hearing was neither requested nor held.
The Secretary followed the process
in section 4672(a)(2)(B) in making this
determination. A review of the stoichiometric material consumption equation and
other information in the petition shows
that the taxable chemicals ethylene and
propylene constitute more than 20 percent by weight of the materials used in
the production of ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n
-(C10H12)o; m=73.18, n=26.53, o=0.29),
based on the predominant method of
production. Therefore, the test in section
4672(a)(2)(B) is satisfied.
(4) Date of determination: June 26,
2026.
(5) Effective dates for addition of ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n-(C10H12)o; m=73.18,
n=26.53, o=0.29) to the List:
(i) Effective date for purposes of the
section 4671 tax (see section 11.01 of Rev.
Proc. 2022-26): October 1, 2026.
Bulletin No. 2026–29
(ii) Effective date for purposes of refund
claims under section 4662(e) (see sections
11.02 and 11.03 of Rev. Proc. 2022-26, as
modified by section 3 of Rev. Proc. 202320): April 1, 2023.
(6) Tax rate prescribed by the Secretary: $9.64 per ton. The conversion factors for the taxable chemicals used in the
production of ethylene-propylene-dicyclopentadiene rubber ((C2H4)m-(C3H6)n
-(C10H12)o; m=73.18, n=26.53, o=0.29) are
0.64 for ethylene and 0.35 for propylene.
The tax rate is calculated by adding the
products of the conversion factor for each
taxable chemical by the tax rate for that
taxable chemical: ((0.64 x $9.74) + (0.35
x $9.74) = $9.64).
(b) Classification numbers.
(1) The Secretary has no basis to object
to the following proposed classification
numbers:
(i) HTSUS number: 4002.70.0000.
(ii) Schedule B number: 4002.70.0000.
(iii) CAS number: 25038-36-2.
(2) The Secretary is unable to confirm the following proposed classification
numbers: Not applicable.
Krishna P. Vallabhaneni,
Tax Legislative Counsel.
26 CFR 601.601: Rules and regulations.
(Also Part I, Sections 530A, 2010, 2503, 2505,
2642, 2662, 6019.)
Transfer Tax Safe Harbor
for Certain Contributions to
Trump Accounts
Rev. Proc. 2026-25
SECTION 1. PURPOSE
This revenue procedure provides a
transfer tax safe harbor for certain individual donors who make one or more contributions to Trump accounts established
under section 530A of the Internal Revenue Code (Code).1 In the interest of sound
tax administration, for taxpayers within
the scope of section 4 of this revenue procedure, contributions to Trump accounts
will be treated as completed gifts that are
not gifts of future interests in property
and to which the annual per-donee gift
tax exclusion applies. As a result, taxpayers within the scope of section 4 of this
revenue procedure will not be required to
file gift tax returns reporting such contributions.
SECTION 2. BACKGROUND
01. Trump accounts.
Section 70204 of Public Law 119‑21,
139 Stat. 72 (July 4, 2025), commonly
known as the One, Big, Beautiful Bill Act,
added section 530A and related provisions
concerning Trump accounts to the Code.
A Trump account is a type of traditional
individual retirement account (IRA) that
is established under section 530A for the
exclusive benefit of an eligible individual
or the eligible individual’s beneficiaries
and is designated as a Trump account at
its establishment. An eligible individual is
any individual (i) who has not attained age
18 before the close of the calendar year in
which an election to open an initial Trump
account (initial Trump account election)
is made, (ii) for whom a social security
number has been issued before the date
of the initial Trump account election, and
(iii) for whom the initial Trump account
election is made. The eligible individual
is the owner of the Trump account and is
referred to as the account beneficiary.
A Trump account is subject to certain
special rules that do not apply to other individual retirement arrangements under section 408, most of which apply only during
the period ending before January 1 of the
calendar year in which the account beneficiary attains age 18. This period is referred
to as the growth period. The special rules
that apply only during the growth period
include a restriction on distributions to the
account beneficiary. Specifically, during
the growth period, no distributions may
be made from a Trump account, except for
qualified rollover contributions, a qual-
ified ABLE rollover contribution (made
only during the calendar year in which an
account beneficiary attains age 17), distributions of excess contributions, and distributions upon the death of the account
beneficiary. Consequently, the account
beneficiary of a Trump account generally
does not have access to amounts in the
Trump account during the growth period.
Trump accounts may receive contributions from nonprofits, governments,
employers, and individuals. During the
growth period, a Trump account is subject to an annual contribution limit of
$5,000, adjusted for inflation after 2027.
This annual limit does not apply to the
$1,000 Trump account pilot program contribution, qualified general contributions
(which are funded by nonprofits and certain governmental entities), or qualified
rollover contributions, but does apply to
any other contribution (including contributions from employers).
As of June 4, 2026, nearly six million
elections to open a Trump account have
been received.
.02 Relevant transfer tax rules.
Individuals and their estates generally are subject to gift, estate, or generation-skipping transfer (GST) tax liability
once the value of cumulative transfers
during life and at death exceed the lifetime basic exclusion amount, which is
currently $15 million (adjusted annually
for inflation). Sections 2010(c), 2505(a),
2631(c).2
The gift tax applies to a transfer of
property by way of gift, whether the transfer is in trust or otherwise, whether the gift
is direct or indirect, and whether the property is real or personal, tangible or intangible. Section 2511(a). The term “taxable
gifts” is defined as the total amount of gifts
made during the calendar year, less any
available deductions (e.g., gift tax marital
or charitable deductions). Section 2503(a).
However, there is an annual per-donee gift
tax exclusion from the total amount of the
donor’s gifts during a calendar year. Specifically, each donor may exclude from the
amount of the donor’s gifts those made to
a particular recipient to the extent the total
Unless otherwise specified, all “section” references are to sections of the Code.
In general terms, if a portability election under section 2010(c)(5) is made by the estate of a predeceasing spouse, the predeceasing spouse’s unused exclusion amount (deceased spousal
unused exclusion or DSUE) is added to the surviving spouse’s basic exclusion amount to increase the value of the surviving spouse’s cumulative transfers exempt from gift and estate tax.
The sum of the basic exclusion amount and any available DSUE amount is the applicable exclusion amount. Section 2010(c)(3).
1
2
Bulletin No. 2026–29
45
July 13, 2026
value of the donor’s gifts to that recipient does not exceed this annual exclusion
amount, provided that those gifts are not
gifts of a future interest in property. Section 2503(b)(1). For calendar year 2026,
the annual exclusion amount (as indexed
for inflation) is $19,000 per individual
recipient, and is available in addition
to the donor’s lifetime basic exclusion
amount (the cumulative amount excluded
from gift and estate taxes).
A taxable gift or transfer at death also
may be subject to GST tax. Section 2601.
Every individual is allowed a lifetime
GST exemption amount, which is equal
to the basic exclusion amount for gift and
estate tax purposes (thus, $15,000,000 for
calendar year 2026). Section 2631(c).
Gifts are also subject to certain reporting requirements. An individual making
one or more gifts generally is required
by section 6019 (and by section 2662 if
the gift also is a direct skip for GST tax
purposes) to file a gift tax return to report
gifts made during the calendar year. The
gift tax return must be filed on or before
the date specified in section 6075(b), generally April 15 of the following calendar
year. If the donor’s total gifts to each
recipient (other than gifts of future interests in property) during the calendar year
are valued at or below the annual per-donee gift tax exclusion amount, those gifts
do not require the filing of a gift tax return.
However, gifts of future interests in property are required to be reported on a gift
tax return because they are not eligible for
the annual per-donee gift tax exclusion.
In FY 2025, the Internal Revenue Service
(IRS) received approximately 300,000
gift tax returns (Form 709).3
SECTION 3. DISCUSSION
The Department of the Treasury
(Treasury Department) and the IRS have
received stakeholder comments and are
aware of public commentary raising questions about the transfer tax consequences
for individual donors who make contri-
butions to Trump accounts, including
whether such contributions constitute taxable gifts that must be reported on a gift tax
return. Such reporting would be required
if contributions to Trump accounts are
treated as gifts of future interests.
The Treasury Department and the IRS
understand the concerns raised in public
comments and recognize that the vast
majority of individual donors to Trump
accounts are unlikely to ever owe federal
gift, estate or GST tax due to the lifetime
basic exclusion amount of $15,000,000
and the corresponding $15,000,000 GST
exemption amount. For many of these
donors, the cost and other burdens of
complying with gift tax reporting requirements could outweigh the anticipated
financial savings benefit of making one or
more contributions to a Trump account.
In addition, gift tax reporting compliance by these donors could dramatically
increase the burden on the IRS to process
gift tax returns for individual donors who
are unlikely to ever be subject to gift,
estate, or GST tax. Given the fact that
nearly 6,000,000 elections to open Trump
accounts have already been received, the
number of gift tax returns filed annually
could be expected to increase from roughly
300,000 to several million. Accordingly,
the Treasury Department and the IRS are
providing a safe harbor, described in section 5 of this revenue procedure, for taxpayers within the scope of section 4 of this
revenue procedure.
SECTION 4. SCOPE
.01 In general. The safe harbor
described in section 5 of this revenue
procedure applies for a particular calendar year only if all of the requirements of
section 4.02 of this revenue procedure are
met.
.02 Requirements.
(1) Taxpayer is an individual;
(2) The only taxable gifts made by the
taxpayer during the calendar year are cash
contributions (in the form of cash, check,
money order, or electronic funds transfer) to one or more Trump accounts, each
made before the calendar year in which
the account beneficiary attains age 18;
(3) The taxpayer’s total gifts during
the calendar year to each individual who
is an account beneficiary, including contributions to that account beneficiary’s
Trump account, do not exceed the annual
exclusion amount under section 2503(b)
($19,000 for 2026);
(4) Such contributions to Trump
accounts made during the calendar year do
not generate for that calendar year either
a gift or GST tax liability, after application of the taxpayer’s remaining applicable credit amount4 against the gift tax, or
remaining GST exemption; and
(5) Disregarding the Trump account
contributions described in section 4.02(2)
of this revenue procedure, no gift tax
return is required to be filed, and no gift
tax return is otherwise filed, for that calendar year by or on behalf of the taxpayer,
whether for GST tax, portability, or other
purposes.5
SECTION 5. SAFE HARBOR
If each of the requirements specified
in section 4.02 of this revenue procedure
is met for a calendar year in which a taxpayer makes contributions to one or more
Trump accounts, each Trump account
contribution made by the taxpayer during
that calendar year will be treated as a completed gift to the account beneficiary that
is not a future interest in property and to
which the annual exclusion applies for
purposes of gift tax, GST tax and gift tax
reporting. As a result, taxpayers within the
scope of section 4 of this revenue procedure will not be required to file a gift tax
return reporting such contributions.
SECTION 6. EXAMPLE
In calendar year 2026 individual donor
(Taxpayer) contributes $5,000 cash to
each of three Trump accounts estab-
2025-I.R.S. Data Book at 4 tbl. 1-2 (2026). See IRS Data Book, Table 1-2, available here: Returns filed, taxes collected and refunds issued | Internal Revenue Service.
The applicable credit amount effectively exempts from federal estate and gift tax an individual’s taxable transfers with a cumulative value not exceeding the applicable exclusion amount.
See section 2010(c).
5
For example, a gift tax return may be required to make affirmative allocations of GST exemption, such as a late allocation of GST exemption to a prior transfer or an allocation at the close
of an estate tax inclusion period (as defined in section 2642(f)(3)), or to make certain GST elections. In addition, a gift tax return may be required as the result of an examination of the estate
tax return.
3
4
July 13, 2026
46
Bulletin No. 2026–29
lished for account beneficiaries A, B, and
C, and makes an additional gift to C of
$13,000 cash. Taxpayer makes no other
gifts during the calendar year and is not
required to, and does not, file a gift tax
return for the calendar year for any other
purpose. The $15,000 in contributions to
Trump accounts do not generate a gift or
GST tax liability, after taking into consideration the Taxpayer’s remaining lifetime
applicable exclusion amount or remaining
GST exemption. Under these facts, the
requirements of section 4.02 of this revenue procedure are met and Taxpayer’s
2026 Trump account contributions will
be treated as completed gifts to A, B, and
C that are not future interests in property.
If instead Taxpayer’s cash gift to C in
2026 is $14,500, the requirement in section 4.02(3) of this revenue procedure is
not met because Taxpayer’s total gifts to
C during calendar year 2026 exceed the
annual per-donee gift tax exclusion under
section 2503(b) of $19,000. Accordingly,
Taxpayer must file a gift tax return for cal-
Bulletin No. 2026–29
endar year 2026 reporting all 2026 gifts,
and must report the Trump account contributions to A, B, and C as gifts of future
interests.
SECTION 7. PAPERWORK
REDUCTION ACT
The Paperwork Reduction Act of 1995
(44 U.S.C. 3501-3520) (PRA) generally
requires that a Federal agency obtain the
approval of the Office of Management and
Budget (OMB) before collecting information from the public, whether such
collection of information is mandatory,
voluntary, or required to obtain or retain
a benefit. An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a valid control number
assigned by the OMB.
Section 4 of this revenue procedure
sets forth safe harbor requirements that
taxpayers may follow for Trump account
contributions to be treated as gifts to
47
which the gift tax annual exclusion under
IRC section 2503(b) applies for purposes
of gift tax, GST tax, and gift tax reporting. Taxpayers should maintain records
sufficient to substantiate compliance with
the safe harbor rules. These recordkeeping requirements are considered general
tax records under §1.6001-1(e). For PRA
purposes, general tax records are already
approved by OMB under 1545-0074 for
individual filers. The revenue procedure
does not impose any additional burden for
taxpayers for purposes of PRA.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue procedure is Rachel K. Downs of
the Office of Associate Chief Counsel
(Passthroughs, Trusts, and Estates). For
further information regarding this revenue procedure, please contact Rachel K.
Downs at (202) 317-6859 (not a toll-free
call).
July 13, 2026
Section 2010. Unified credit against
estate tax
Section 2505. Unified credit against gift
tax
Section 2662.
Return requirements
26 C.F.R. 20.2010-1: Unified credit
against estate tax; in general.
26 C.F.R. 25.2505-1: Unified credit
against gift tax; in general.
26 C.F.R. 26.2662-1: Generationskipping transfer tax return requirements.
This revenue procedure provides a
safe harbor for individual taxpayers who
(i) make contributions to Trump accounts
established under § 530A of the Internal Revenue Code and (ii) meet certain
requirements. If the requirements are met,
contributions to Trump accounts will be
treated as completed gifts that are not
future interests in property and to which
the annual per-donee gift tax annual exclusion applies under § 2503(b). As a result,
taxpayers within the scope of the revenue
procedure will not be required to file gift
tax returns reporting such contributions.
See Rev. Proc. 2026-25, page 45.
This revenue procedure provides a
safe harbor for individual taxpayers who
(i) make contributions to Trump accounts
established under § 530A of the Internal Revenue Code and (ii) meet certain
requirements. If the requirements are met,
contributions to Trump accounts will be
treated as completed gifts that are not
future interests in property and to which
the annual per-donee gift tax annual exclusion applies under § 2503(b). As a result,
taxpayers within the scope of the revenue
procedure will not be required to file gift
tax returns reporting such contributions.
See Rev. Proc. 2026-25, page 45.
This revenue procedure provides a
safe harbor for individual taxpayers who
(i) make contributions to Trump accounts
established under § 530A of the Internal Revenue Code and (ii) meet certain
requirements. If the requirements are met,
contributions to Trump accounts will be
treated as completed gifts that are not
future interests in property and to which
the annual per-donee gift tax annual exclusion applies under § 2503(b). As a result,
taxpayers within the scope of the revenue
procedure will not be required to file gift
tax returns reporting such contributions.
See Rev. Proc. 2026-25, page 45.
Section 2503(b). Exclusion from Gifts
Section 2642(c)(3). Treatment of certain
direct skips which are nontaxable gifts
Section 6019. Gift Tax Returns
26 C.F.R. 25.2503-2: Exclusions from
gifts.
This revenue procedure provides a
safe harbor for individual taxpayers
who (i) make contributions to Trump
accounts established under § 530A of
the Internal Revenue Code and (ii) meet
certain requirements. If the requirements are met, contributions to Trump
accounts will be treated as completed
gifts that are not future interests in property and to which the annual per-donee
gift tax annual exclusion applies under
§ 2503(b). As a result, taxpayers within
the scope of the revenue procedure will
not be required to file gift tax returns
reporting such contributions. See Rev.
Proc. 2026-25, page 45.
July 13, 2026
26 C.F.R. 26.2642-1(c)(3): Nontaxable
gifts.
This revenue procedure provides a
safe harbor for individual taxpayers who
(i) make contributions to Trump accounts
established under § 530A of the Internal Revenue Code and (ii) meet certain
requirements. If the requirements are met,
contributions to Trump accounts will be
treated as completed gifts that are not
future interests in property and to which
the annual per-donee gift tax annual exclusion applies under § 2503(b). As a result,
taxpayers within the scope of the revenue
procedure will not be required to file gift
tax returns reporting such contributions.
See Rev. Proc. 2026-25, page 45.
48
26 C.F.R. 25.6019-1: Persons required to
file returns.
This revenue procedure provides a
safe harbor for individual taxpayers
who (i) make contributions to Trump
accounts established under § 530A of
the Internal Revenue Code and (ii) meet
certain requirements. If the requirements are met, contributions to Trump
accounts will be treated as completed
gifts that are not future interests in property and to which the annual per-donee
gift tax annual exclusion applies under
§ 2503(b). As a result, taxpayers within
the scope of the revenue procedure will
not be required to file gift tax returns
reporting such contributions. See Rev.
Proc. 2026-25, page 45.
Bulletin No. 2026–29
Part IV
Optional Standard Mileage Rates
Announcement 2026-11
This announcement informs taxpayers that the Internal Revenue Service is modifying Notice 2026-10, 2026-4 I.R.B. 378, by
revising the optional standard mileage rates for computing the deductible costs of operating an automobile for business, medical, or
moving expense purposes and for determining the reimbursed amount of these expenses that is deemed substantiated. This modification results from recent increases in the price of fuel.
The revised standard mileage rates are:
(1) Business
(2) Medical and moving
76 cents per mile
23.5 cents per mile
The mileage rate that applies to the deduction for charitable contributions is fixed under § 170(i) of the Internal Revenue Code at
14 cents per mile.
The revised standard mileage rates set forth in this announcement apply to deductible transportation expenses paid or incurred
for business, medical, or moving expense purposes on or after July 1, 2026, and to mileage allowances that are paid both (1) to an
employee on or after July 1, 2026, and (2) for transportation expenses paid or incurred by the employee on or after July 1, 2026.
The standard mileage rates set forth in Notice 2026-10 continue to apply to deductible transportation expenses paid or incurred for
business, medical, or moving expense purposes before July 1, 2026, and to mileage allowances paid (1) to an employee before July
1, 2026, or (2) with respect to transportation expenses paid or incurred by the employee before July 1, 2026.
All other provisions of Notice 2026-10 remain in effect.
EFFECT ON OTHER DOCUMENTS
Notice 2026-10 is modified.
DRAFTING INFORMATION
The principal author of this announcement is Christian Lagorio of the Office of Chief Counsel (Income Tax and Accounting).
For further information regarding this announcement contact Mr. Lagorio at (202) 317-7005 (not a toll-free number).
Bulletin No. 2026–29
49
July 13, 2026
Deletions From Cumulative List of Organizations, Contributions to Which are
Deductible Under Section 170 of the Code
Announcement 2026-12
Table of Contents
The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in
sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.
Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a
deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or
determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities
or omissions of the organization that brought about this revocation.
If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described
in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on
June 24, 2026, and would end on the date the court first determines the organization is not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband
and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the
organization that were the basis for revocation.
Name Of Organization
Preserve Silver Lake Fund
Community School of New Hope
ACTS Community Development Corporation
Treasure County Senior Citizens
Effective Date of Revocation
08/01/2022
01/01/2022
01/01/2022
07/01/2022
July 13, 2026
50
Location
Lewisberry, PA
New Hope, PA
Brooklyn, NY
Hysham, MT
Bulletin No. 2026–29
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. 2026–29
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.
July 13, 2026
Numerical Finding List1
Bulletin 2026–29
Announcements:
2026-11, 2026-29 I.R.B. 49
2026-12, 2026-29 I.R.B. 50
Notices:
2026-39, 2026-27 I.R.B. 1
2026-38, 2026-28 I.R.B. 30
2026-40, 2026-28 I.R.B. 33
2026-41, 2026-29 I.R.B. 39
2026-42, 2026-29 I.R.B. 41
2026-43, 2026-29 I.R.B. 42
Revenue Procedures:
2026-25, 2026-29 I.R.B. 45
Revenue Rulings:
2026-12, 2026-28 I.R.B. 27
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin
2025–52, dated December 21, 2025.
1
July 13, 2026
ii
Bulletin No. 2026–29
Finding List of Current Actions on
Previously Published Items1
Bulletin 2026–29
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin
2025–52, dated December 21, 2025.
1
Bulletin No. 2026–29
iii
July 13, 2026
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
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