Internal Revenue Bulletin 2026-25 (PDF rendition): IRS Notices

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Bulletin No. 2026–25
June 15, 2026
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2026-24, page 1582.
Revenue Procedure 2026-24 provides the 2027 inflation
adjusted amounts for Health Savings Accounts (HSAs) as
determined under section 223 of the Internal Revenue Code
(Code) and the maximum amount that may be made newly
available for excepted benefit health reimbursement arrange-
ments (HRAs) provided under § 54.9831-1(c)(3)(viii) of the
Pension Excise Tax Regulations.
EMPLOYEE PLANS
Notice 2026-32, page 1578.
This notice provides that a broker-dealer that carries cus-
tomer accounts and receives or holds funds or securities
for those customers may, in lieu of demonstrating satisfac-
tion of the adequacy of net worth requirement for nonbank
trustees under § 1.408-2(e)(5)(ii), demonstrate satisfaction
of Rule 15c3-1 (SEC Net Capital Rule) and Rule 15c3-3 (SEC
Customer Protection Rule) under the Securities Exchange
Act of 1934.
INCOME TAX
CC-00349656-26, page 1583.
These proposed regulations would withdraw applicability
dates and propose new applicability dates relating to pro-
posed regulations under section 892 of the Internal Reve-
nue Code for determining whether an acquisition of debt by
a foreign government is commercial activity and whether a
foreign government has effective control of an entity. These
proposed regulations would provide transitional relief to
existing holdings of foreign governments when finalized.
Notice 2026-35, page 1580.
This notice publishes the applicable percentage under §
613A(c)(6)(C) of the Internal Revenue Code for calendar
year 2026. The applicable percentage is used in computing
the allowance for depletion under § 611 for oil and natural
gas produced from marginal properties.
Finding Lists begin on page ii.

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 offi-
cial 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 sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of inter-
nal 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 rul-
ings 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, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
June 15, 2026 Bulletin No. 2026–25

Part III
Alternative Method for
Carrying Broker-Dealers
to Comply with Certain
Nonbank Trustee Rules
Notice 2026-32
I. PURPOSE
This notice provides that, pursuant
to § 1.408-2(e)(6)(ii) of the Income Tax
Regulations, a broker-dealer that carries
customer accounts and receives or holds
funds or securities for those customers
(a carrying broker-dealer) may, in lieu of
demonstrating satisfaction of the adequacy
of net worth requirement for nonbank
trustees under § 1.408-2(e)(5)(ii), demon-
strate satisfaction of Rule 15c3-1 (SEC
Net Capital Rule) and Rule 15c3-3 (SEC
Customer Protection Rule) (together, SEC
Net Capital and Customer Protection
Rules) of the Securities Exchange Act of
1934, as amended (Exchange Act).
1
This
notice also describes procedures regarding
demonstration by a carrying broker-dealer
of satisfaction of the SEC Net Capital and
Customer Protection Rules and requests
public comments on related topics.
2

II. BACKGROUND
A. Background on IRS Nonbank Trustee
Rules
Section 408(a) of the Internal Revenue
Code provides that an individual retirement
account (IRA) is a trust created or organized
in the United States for the exclusive bene-
fit of an individual or the individual’s ben-
eficiaries, but only if the written governing
instrument creating the trust meets certain
requirements. One such requirement, under
section 408(a)(2), is that the trustee of an
IRA must be a bank (as defined in section
408(n)) or “such other person who demon-
strates to the satisfaction of the Secretary
that the manner in which such other person
will administer the trust will be consistent
with the requirements of this section.”
3

In order for an entity that is not a bank to
qualify as an IRA trustee (i.e., a nonbank
trustee), § 1.408-2(e) imposes several
requirements, including fiduciary conduct
requirements.
4
Section 1.408-2(e)(2) requires that
an applicant for nonbank trustee status
demonstrate its ability to act within the
accepted rules of fiduciary conduct by
including in its demonstration certain ele-
ments of proof. Under § 1.408-2(e)(2)(iv),
one of these required elements of proof is
to assure compliance with the fiduciary
conduct provisions set out in § 1.408-2(e)
(5). Under § 1.408-2(e)(5), the applicant
must demonstrate that, under applicable
regulatory requirements, corporate or
other governing instruments, or its estab-
lished operating procedures, it satisfies
certain rules of fiduciary conduct, includ-
ing the adequacy of net worth requirement
under § 1.408-2(e)(5)(ii).
5
To comply with
this requirement, a nonbank trustee’s net
worth generally must exceed the greater
of (i) a specified dollar amount or (ii) a
percentage of the value of all assets held
in fiduciary accounts. However, that per-
centage test is modified under § 1.408-
2(e)(5)(ii)(D) in the case of a nonbank
trustee that is a member of the Securities
Investor Protection Corporation (SIPC).
A key objective of this adequacy of net
worth requirement is to ensure that non-
bank trustees maintain a level of solvency
commensurate with their financial and
fiduciary responsibilities.
6

Section 1.408-2(e) provides flexibility
for the Internal Revenue Service (IRS) to
apply the nonbank trustee requirements
under certain circumstances involving
overlapping regulatory requirements. Spe-
cifically, § 1.408-2(e)(6)(ii) provides that
“[e]vidence that an applicant is subject to
Federal or State regulation with respect to
one or more relevant factors shall be given
weight in proportion to the extent that
such regulatory standards are consonant
with the requirements of section [408]”
7

and such evidence may be submitted “in
addition to, or in lieu of,” the specific
proofs required by § 1.408-2(e).
B. Background on Exchange Act Rules
15c3-1 and 15c3-3
8
Carrying broker-dealers are subject
to prescriptive regulation by the Securi-
ties and Exchange Commission (SEC),
including rules that aim to ensure car-
rying broker-dealers maintain a level
of solvency commensurate with their
financial responsibilities. The SEC Cus-
tomer Protection Rule, as codified by the
SEC in 17 CFR 240.15c3-3, is designed
to give specific protection to customer
funds and securities (for example, IRA
assets), in effect forbidding carrying bro-
ker-dealers from using customer assets to
finance any part of their business unre-
lated to servicing securities customers.
To meet this objective, the SEC Cus-
tomer Protection Rule requires a carrying
broker-dealer to take two primary steps
to safeguard customer assets, which are
designed to protect customers by seg-
regating their securities and cash from
the carrying broker-dealer’s proprietary
business activities.
The first step to safeguard customer
assets under the SEC Customer Protec-
1
Pub. L. 73-291, 48 Stat. 881.
2
The guidance in this notice does not apply to a broker-dealer that operates pursuant to an exemption report under SEC Rule 17a-5(d) (17 CFR § 240.17a-5).
3
Nonbank trustees can be approved by the IRS to hold certain other types of fiduciary accounts, such as certain custodial accounts, Trump accounts, and health savings accounts. See section
3.07 of Rev. Proc. 2026-4, 2026-1 IRB 160 (updated annually).
4
The nonbank trustee rules also apply with respect to IRAs that are custodial accounts. See section 408(h) and § 1.408-2(d).
5
Under § 1.408-2(e)(5)(viii)(F), the term “net worth” is defined as “the amount of the applicant’s assets less the amount of its liabilities, as determined in accordance with generally accepted
accounting principles.”
6
See T.D. 8635, 60 Fed. Reg. 65547, 65548 (Dec. 20, 1995).
7
The final regulation points to section 401 (i.e., rules for qualification of employer-sponsored retirement plans); however, the reference is an artifact of the regulation’s original publication as
part of the regulations under section 401 and, thus, should be read as referring to section 408, which contains the IRA requirements.
8
Personnel from the Department of the Treasury (Treasury Department) and the IRS consulted with SEC staff in developing the description of the SEC Net Capital and Customer Protection
Rules discussed in this section, and that description was reviewed by SEC staff.
June 15, 2026 1578 Bulletin No. 2026–25

tion Rule requires carrying broker-deal-
ers to maintain physical possession or
control over customers’ fully paid and
excess margin securities.
9
The second
step requires that a carrying broker-dealer
maintain a reserve of cash or qualified
securities in an account at a third-party
bank that is at least equal in value to the
net cash owed to customers, including
cash obtained from the use of customer
securities, determined by a computation
of the broker-dealer’s customer credit
items (for example, cash in customer
securities accounts and cash obtained
through the use of customer margin secu-
rities) subtracted by the broker-dealer’s
customer debit items (for example, margin
loans). If credit items exceed debit items,
the net amount must be on deposit in the
customer reserve bank account in the form
of cash and/or qualified securities. Sub-
ject to certain exceptions, the SEC Cus-
tomer Protection Rule requires a carrying
broker-dealer to make this calculation of
the required deposit amount on a weekly
basis.
The SEC Customer Protection Rule
operates in tandem with the SEC Net Cap-
ital Rule, as codified in 17 CFR 240.15c3-
1. The SEC Net Capital Rule is designed
to prevent a broker-dealer’s insolvency
by preventing excessive credit or mar-
ket risk positions. Among other require-
ments, a broker-dealer must maintain a
minimum level of net capital under the
rules of 17 CFR 240.15c3-1 at all times,
and not be “insolvent” as defined in that
rule.
10
The SEC has explained that “[t]he
objective of Rule 15c3-1 is to require a
broker-dealer to maintain sufficient liq-
uid assets to meet all liabilities, including
obligations to customers, counterparties,
and other creditors and to have adequate
additional resources to wind-down its
business in an orderly manner without
the need for a formal proceeding if the
firm fails financially.”
11

Pursuant to the Securities Investor
Protection Act of 1970 (SIPA),
12
carrying
broker-dealers are required to be mem-
bers of SIPC, which generally protects
each customer of a failed SIPC-member
broker-dealer up to $500,000, including
up to $250,000 for cash claims. The SEC
Customer Protection Rule supports SIPA’s
customer-protection objective by requir-
ing carrying broker-dealers to segregate
customers’ securities and cash from the
broker-dealer’s proprietary business activ-
ities. Through this requirement, the SEC
Customer Protection Rule is designed to
ensure that, if the carrying broker-dealer
fails financially, the customer securities
and cash should be readily available to be
returned to customers, which facilitates
an orderly self-liquidation. However, if
the failed carrying broker-dealer is liqui-
dated under SIPA, the customer securities
and cash should be isolated and readily
identifiable as “customer property” and,
consequently, available to be distributed
to customers ahead of other creditors.
13
In
addition, the Financial Industry Regula-
tory Authority (FINRA), acting as the des-
ignated examining authority for carrying
broker-dealers, examines carrying bro-
ker-dealers’ compliance with the SEC’s
financial responsibility rules, including
the SEC Net Capital and Customer Pro-
tection Rules.
III. GUIDANCE
Stakeholders have asked the Depart-
ment of the Treasury (Treasury Depart-
ment) and the IRS whether, for purposes
of compliance with the nonbank trustee
fiduciary conduct requirements under
§ 1.408-2(e)(5), the regulatory standards
imposed on carrying broker-dealers by the
SEC Net Capital and Customer Protection
Rules are consonant with the adequacy of
net worth requirement under § 1.408-2(e)
(5)(ii), so that, under § 1.408-2(e)(6)(ii),
evidence of satisfaction of the SEC Net
Capital and Customer Protection Rules
by a carrying broker-dealer could be sub-
mitted to the IRS in lieu of evidence of
satisfaction of the adequacy of net worth
requirement.
A. Carrying Broker-Dealers May
Demonstrate Satisfaction of the SEC Net
Capital and Customer Protection Rules
in Lieu of the Adequacy of Net Worth
Requirement
The SEC Net Capital and Customer Pro-
tection Rules address the same core finan-
cial responsibility concerns reflected in the
adequacy of net worth requirement under
§ 1.408-2(e)(5)(ii), including the solvency
of an entity holding customer accounts
and the protection of customer accounts.
In addition, carrying broker-dealers sub-
ject to the SEC Net Capital and Customer
Protection Rules are subject to substantial
oversight, including by FINRA. Accord-
ingly, for carrying broker-dealers, the
SEC Net Capital and Customer Protection
Rules are consonant with the adequacy
of net worth requirement under § 1.408-
2(e)(5)(ii). Thus, pursuant to § 1.408-
2(e)(6)(ii), a carrying broker-dealer may
demonstrate satisfaction of the SEC Net
Capital and Customer Protection Rules
in lieu of demonstrating satisfaction of
the adequacy of net worth requirement
for nonbank trustees under § 1.408-2(e)
(5)(ii). This alternative demonstration
is not available to a broker-dealer that
operates pursuant to an exemption report
under SEC Rule 17a-5(d). Comments are
requested on circumstances under which a
carrying broker-dealer that has indicated it
9
“Control” means the carrying broker-dealer holds these securities in one of several locations specified in SEC Exchange Act Rule 15c3-3 and free of liens or any other interest that could be
exercised by a third-party to secure an obligation of the carrying broker-dealer. See 17 CFR 240.15c3-3(c). Permissible locations include a clearing corporation and a “bank,” as defined in
section 3(a)(6) of the Exchange Act. A carrying broker-dealer does not treat customer securities as its own assets. Rather, the carrying broker-dealer holds them in a custodial capacity, and the
possession and control requirement is designed to ensure that the carrying broker-dealer treats them in a manner that allows for their prompt return.
10
For this purpose, “net capital” is defined in SEC Exchange Act Rule 15c3-1(c)(2) as “the net worth of a broker or dealer, adjusted by” deductions for certain illiquid assets along with certain
percentages from its proprietary securities or commodities inventory (for example, a 100% haircut for “non-marketable” securities and a 20% haircut for commodities), and additions back of
certain liabilities to arrive at net capital. One such “add-back” adjustment is for “liabilities of the broker or dealer which are subordinated to the claims of creditors pursuant to a satisfactory
subordination agreement.”
11
See 84 FR 43872, 43879 (Aug. 22, 2019).
12
Pub. L. 91-598, 84 Stat. 1636, codified at 15 U.S.C. § 78aaa et seq.
13
Of the approximately 770,400 claims satisfied in completed liquidations of broker-dealers under SIPA, as of December 31, 2025, a total of 355 were for cash and securities whose value was
greater than the limits of protection afforded by SIPA. The 355 claims represent less than one percent of all claims satisfied. The unsatisfied portion of claims, $49.7 million, represents less
than one percent of the total value of securities and cash distributed for accounts of customers in the 329 completed cases. See 2025 SIPC Annual Report.
Bulletin No. 2026–25 1579 June 15, 2026

June 15, 2026 1580 Bulletin No. 2026–25
is satisfying the SEC Net Capital and Cus-
tomer Protection Rules would be treated
as no longer satisfying those rules and,
therefore, would no longer be eligible to
demonstrate satisfaction of the SEC Net
Capital and Customer Protection Rules in
lieu of the adequacy of net worth require-
ment.
B. Procedures for Existing Nonbank
Trustees That Are Carrying Broker-
Dealers
A carrying broker-dealer that has
received a nonbank trustee notice of
approval from the IRS based on satisfac-
tion of the adequacy of net worth require-
ment of § 1.408-2(e)(5)(ii) and would like
to demonstrate satisfaction of the SEC Net
Capital and Customer Protection Rules in
lieu of the adequacy of net worth require-
ment must notify the IRS in accordance
with § 1.408-2(e)(6)(iv).
C. Procedures for Nonbank Trustee
Applicants That Are Carrying Broker-
Dealers
The procedures for applying to the
IRS to become a nonbank trustee are
described in Rev. Proc. 2026-4 (updated
annually). The Treasury Department and
the IRS anticipate updating the proce-
dures for nonbank trustee applicants that
are carrying broker-dealers that want to
demonstrate satisfaction of the SEC Net
Capital and Customer Protection Rules
in lieu of the adequacy of net worth
requirement. Until the procedures are
updated, applicants may demonstrate
satisfaction of the SEC Net Capital and
Customer Protection Rules by applying
a reasonable, good faith interpretation of
this notice and Rev. Proc. 2026-4. Com-
ments are requested on how these proce-
dures should be updated, including what
documentation a carrying broker-dealer
should be required to submit with its
application to demonstrate satisfaction of
the SEC Net Capital and Customer Pro-
tection Rules, such as the carrying bro-
ker-dealer’s most recent: (1) Financial
and Operational Combined Uniform Sin-
gle Report (“FOCUS Report”), Part II;
and (2) audited annual report including
a facing page (Form X-17A-5 Part III),
statement of financial condition, state-
ment of income, net capital computation,
statement of cash flows, statement of
changes in stockholders’ or sole propri-
etor’s equity, statement of changes in lia-
bilities subordinated to claims of general
creditors, and compliance report.
IV. APPLICABILITY DATE
This notice applies as of May 21, 2026.
V. REQUEST FOR COMMENTS
The Treasury Department and the
IRS request comments as described in
section III of this notice. Written com-
ments should be submitted by July 20,
2026. The subject line for the com-
ments should include a reference to
Notice 2026-32. Comments may be
submitted electronically via the Fed-
eral eRulemaking Portal at https://www.
regulations.gov (type IRS-2026-0628 in
the search field on the regulations.gov
homepage to find this notice and submit
comments). Alternatively, comments
may be submitted by mail to: Internal
Revenue Service, CC:PA:01:PR (Notice
2026-32), Room 5503, P.O. Box 7604,
Ben Franklin Station, Washington, DC
20044. All commenters are strongly
encouraged to submit comments elec-
tronically. The Treasury Department and
the IRS will publish for public availabil-
ity any comment submitted electron-
ically, or on paper, to the IRS’s public
docket on https://www.regulations.gov.
VI. PAPERWORK REDUCTION ACT
The Paperwork Reduction Act of 1995
(44 U.S.C. 3501-3520) (PRA) generally
requires that a Federal agency obtain
approval from the Office of Manage-
ment and Budget (OMB) before collect-
ing information from the public, whether
such collection is mandatory, voluntary, or
required to obtain or retain a benefit. An
agency may not conduct or sponsor, and a
person is not required to respond to, a col-
lection of information unless it displays a
valid OMB control number.
This notice does not impose any new
reporting, recordkeeping, or third-party
disclosure requirements. Section III of
this notice describes procedures for exist-
ing nonbank trustees that are carrying
broker-dealers, as well as procedures for
nonbank trustee applicants that are carry-
ing broker-dealers under existing regula-
tions (§ 1.408-2(e)(6)(iv)) and Rev. Proc.
2026-4. These requirements are already
approved under OMB Control Numbers
1545-0930 and 1545-1520.
VII. DRAFTING INFORMATION
The principal author of this notice is
the Office of Associate Chief Counsel
(Employee Benefits, Exempt Organiza-
tions, and Employment Taxes). For fur-
ther information regarding this notice,
please contact (202) 317-6000 (not a toll-
free number).
2026 Marginal Production
Rates
Notice 2026-35
This notice announces the applicable
percentage under § 613A of the Internal
Revenue Code to be used in determining
percentage depletion for marginal proper-
ties for the 2026 calendar year.
Section 613A(c)(6)(C) defines the term
“applicable percentage” for purposes of
determining percentage depletion for oil
and gas produced from marginal prop-
erties. The applicable percentage is the
percentage (not greater than 25 percent)
equal to the sum of 15 percent, plus one
percentage point for each whole dollar
by which $20 exceeds the reference price
(determined under § 45K(d)(2)(C)) for
crude oil for the calendar year preceding
the calendar year in which the taxable year
begins. The reference price determined
under § 45K(d)(2)(C) for the 2025 calen-
dar year is $63.40. Accordingly, 15% is
the applicable percentage under § 613A to
be used in determining percentage deple-
tion for marginal properties for the 2026
calendar year.
The following table contains the appli-
cable percentages for marginal production
for taxable years beginning in calendar
years 1991 through 2026.

Bulletin No. 2026–25 1581 June 15, 2026
Applicable Percentage for Marginal Production
Calendar YearApplicable Percentage
199115 percent
199218 percent
199319 percent
199420 percent
199521 percent
199620 percent
199716 percent
199817 percent
199924 percent
200019 percent
200115 percent
200215 percent
200315 percent
200415 percent
200515 percent
200615 percent
200715 percent
200815 percent
200915 percent
201015 percent
201115 percent
201215 percent
201315 percent
201415 percent
201515 percent
201615 percent
201715 percent
201815 percent
201915 percent
202015 percent
202115 percent
202215 percent
202315 percent
202415 percent
202515 percent
202615 percent
The principal author of this notice
is Alan W. Tilley of the Office of Asso-
ciate Chief Counsel (Energy, Credits,
and Excise Tax). For further information
regarding this notice, contact Mr. Tilley
at (317) 512-6512 (not a toll-free num-
ber).

June 15, 2026 1582 Bulletin No. 2026–25
26 CFR 601.602: Tax forms and instructions.
(Also: Part I, §§ 1, 223, Part III § 54.9831-1)
Rev. Proc.2026-24
SECTION 1. PURPOSE
This revenue procedure provides
the 2027 inflation adjusted amounts for
Health Savings Accounts (HSAs) as deter-
mined under section 223 of the Internal
Revenue Code (Code) and the maximum
amount that may be made newly available
for excepted benefit health reimbursement
arrangements (HRAs) provided under
§ 54.9831-1(c)(3)(viii) of the Pension
Excise Tax Regulations.
SECTION 2. LEGISLATIVE
CHANGES
.01 Section 71308 of Public Law 119-
21, 139 Stat. 72, 325-326 (July 4, 2025),
commonly known as the One, Big, Beau-
tiful Bill Act, added section 223(c)(1)(E)
to the Code. Under section 223(c)(1)(E),
a direct primary care service arrangement
(DPCSA) shall not be treated as a health
plan for the purposes of section 223(c)
(1)(A)(ii) provided that, with respect to
any individual for any month, the aggre-
gate fees for all DPCSAs with respect to
the individual do not exceed $150 ($300
in the case of an individual with any
DPCSA that covers more than one indi-
vidual). Section 223(c)(1)(E) is effective
for months beginning after December 31,
2025. The $150 and $300 amounts are
adjusted for inflation for months begin-
ning after December 31, 2026.
SECTION 3. 2027 INFLATION
ADJUSTED ITEMS
.01 HSA Inflation Adjusted Items.
(1) Annual contribution limitation. For
calendar year 2027, the annual limitation
on deductions under section 223(b)(2)
(A) for an individual with self-only cov-
erage under a high deductible health plan
is $4,500. For calendar year 2027, the
annual limitation on deductions under sec-
tion 223(b)(2)(B) for an individual with
family coverage under a high deductible
health plan is $9,000.
(2) Maximum monthly aggregate fees
for all DPCSAs. For calendar year 2027, a
DPCSA is not treated as a health plan with
respect to an otherwise eligible individual
if the aggregate monthly fees for all DPC-
SAs with respect to the individual do not
exceed $150 or, if the individual is cov-
ered by a DPCSA that covers more than
one individual, $300.
(3) High deductible health plan. For
calendar year 2027, a “high deductible
health plan” is defined under section
223(c)(2)(A) as a health plan with an
annual deductible that is not less than
$1,750 for self-only coverage or $3,500
for family coverage, and for which the
annual out-of-pocket expenses (deduct-
ibles, co-payments, and other amounts,
but not premiums) do not exceed $8,700
for self-only coverage or $17,400 for fam-
ily coverage.
.02 HRA Inflation Adjusted Item.
For plan years beginning in 2027,
the maximum amount that may be made
newly available for the plan year for an
excepted benefit HRA under § 54.9831-
1(c)(3)(viii) is $2,250. See § 54.9831-1(c)
(3)(viii)(B)(1) for further explanation of
this calculation.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for
HSAs for calendar year 2027, for DPC-
SAs for months beginning in calendar
year 2027, and for excepted benefit HRAs
for plan years beginning in 2027.
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Michael Finn of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding the calculations in this revenue
procedure contact Mr. Finn at (202) 317-
4718 (not a toll-free number). For further
information regarding section 223, HSAs,
DPCSAs and excepted benefit HRAs,
contact the Health and Welfare Branch
in the Office of Associate Chief Counsel
(Employee Benefits, Exempt Organiza-
tions, and Employment Taxes) at (202)
317-5500 (not a toll-free number).

Bulletin No. 2026–25 1583 June 15, 2026
Part IV
Notice of Proposed
Rulemaking
Income of Foreign
Governments and of
International Organizations
CC-00349656-26
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing; partial withdrawal of proposed
rulemaking.
SUMMARY: This document contains
proposed regulations regarding the appli-
cability dates of proposed rules relating to
the taxation of the income of foreign gov-
ernments from investment in the United
States. This document also withdraws a
portion of the proposed regulations pub-
lished on December 15, 2025, relating to
applicability dates.
DATES: Written or electronic comments
and requests for a public hearing must be
received by July 31, 2026. As of June 1,
2026, proposed §§ 1.892-4(d) and 1.892-
5(e), contained in the notice of proposed
rulemaking published in the Federal
Register on December 15, 2025 (90 FR
57928), are withdrawn.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically via the Federal eRulemak-
ing Portal at https://www.regulations.
gov (indicate IRS and CC-00349656-
26) by following the online instructions
for submitting comments. Requests for a
public hearing must be submitted as pre-
scribed in the “Comments and Requests
for a Public Hearing” section. Once
submitted to the Federal eRulemak-
ing Portal, comments cannot be edited
or withdrawn. The Department of the
Treasury (Treasury Department) and the
IRS will publish for public availability
any comments submitted to the IRS’s
public docket. Send paper submissions
to: CC:PA:01:PR (CC-00349656-26),
Room 5503, Internal Revenue Service,
P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044.
FOR FURTHER INFORMATION
CONTACT: Concerning the proposed
regulations, Jack Zhou at (202) 317-6938;
concerning submissions of comments,
requests for a public hearing, and access
to a public hearing, Publication and Reg-
ulations Section at (202) 317-6901 (not
toll-free numbers) or by email to publi-
chearings@irs.gov (preferred).
SUPPLEMENTARY INFORMATION:
Authority
This document contains proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1) under section 892 of
the Internal Revenue Code (Code). These
proposed regulations are issued under the
express delegations of authority under
sections 892(c) and 7805(a) of the Code.
Background
I. 2025 Proposed Regulations under
Section 892
On December 15, 2025, the Trea-
sury Department and the IRS published
in the Federal Register (90 FR 57928)
proposed regulations (the 2025 proposed
regulations) under section 892 relating
to taxation of the income of foreign gov-
ernments from investments in the United
States. The 2025 proposed regulations
would provide guidance for determining
whether an acquisition of debt is com-
mercial activity, and whether a foreign
government has effective control of an
entity. See proposed §§ 1.892-4(c)(1)(ii)
and 1.892-5(c)(2). The 2025 proposed
regulations are proposed to apply to tax-
able years beginning on or after the date
of publication of the Treasury decision
adopting the 2025 proposed regulations
as final regulations (the final regula-
tions). See proposed §§ 1.892-4(d) and
1.892-5(e).
II. Comments on the Proposed
Applicability Dates
Following the publication of the
2025 proposed regulations, the Treasury
Department and the IRS received com-
ments requesting transitional relief with
respect to the proposed applicability dates.
Commenters requested that the proposed
debt acquisition rules, when finalized,
apply only to debt instruments acquired
on or after the publication date of the final
regulations (the publication date). Com-
menters also requested a rule that would
preserve the application of existing rules
under section 892 to debt acquired before
the publication date and to debt acquired
on or after the publication date pursuant
to a legally binding commitment entered
into before the publication date. Alterna-
tively, a commenter requested an extended
period of time after the publication date
during which foreign governments could
continue relying on the existing rules for
outstanding debt instruments and commit-
ments while they reposition their interests
to accord with the final regulations. In
addition, a commenter requested a transi-
tion rule that would preserve the applica-
tion of existing rules for debt instruments
acquired on or before 90 days after the
publication date of the final regulations
and for debt instruments acquired after
that date but pursuant to a binding com-
mitment entered into on or before that
date.
Likewise, commenters requested that
the proposed effective control rules, when
finalized, apply only to rights granted (or
materially expanded) on or after the publi-
cation date. Commenters recommended a
rule that would preserve the application of
existing rules under section 892 to arrange-
ments in place before the publication date
as well as to entity interests acquired pur-
suant to legally binding commitments
entered into before the publication date.
Alternatively, commenters requested an
extended period after the publication date
during which foreign governments may
continue relying on the existing rules
with respect to existing interests, and not
have to consider renegotiating or restruc-
turing certain legacy holdings solely due

June 15, 2026 1584 Bulletin No. 2026–25
to the final regulations. Similarly, one
commenter requested a transition rule
that would preserve the application of the
existing rules for agreements and other
arrangements entered into on or before 90
days after the publication date.
Explanation of Provisions
I. New Proposed Applicability Dates
As a general matter, the Treasury
Department and the IRS did not intend
for the 2025 proposed regulations, once
finalized, to apply retroactively to existing
foreign government holdings of debt and
of interests in entities (collectively, for-
eign government holdings). In addition, in
response to the comments, these proposed
regulations would include additional tran-
sitional relief. Accordingly, this notice
of proposed rulemaking withdraws the
applicability dates in §§ 1.892-4(d) and
1.892-5(e) of the 2025 proposed regula-
tions and proposes new applicability dates
to ensure that certain existing foreign
government holdings, as well as holdings
acquired during a transition period, would
not be subject to the final regulations. The
existing rules under section 892 would
continue to apply to foreign government
holdings acquired before the applicability
date and to foreign government holdings
acquired on or after the applicability date
if acquired pursuant to a binding commit-
ment entered into before the applicability
date.
These proposed regulations would
address only the proposed applicability
dates of the 2025 proposed regulations.
The Treasury Department and the IRS
recognize the importance of the issues
raised by stakeholders on the substan-
tive aspects of the 2025 proposed reg-
ulations. The Treasury Department and
the IRS have received 18 comments on
the 2025 proposed regulations—includ-
ing with respect to the debt acquisition
rules and the effective control rules—
and are evaluating how to reflect these
comments in the next phase of this proj-
ect by taking into account established
market practices and the general policy
to support current and future sovereign
wealth fund investment in the United
States. Any terms used but not defined
in this preamble have the meanings
given to them in the 2025 proposed reg-
ulations.
II. Applicability Date for Debt
Acquisition Rules
Proposed § 1.892-4(d)(2) would pro-
vide foreign governments with a transition
period of at least 90 days after the publica-
tion date, or until the start of the first tax-
able year after the publication date, before
the debt acquisition rules in the final reg-
ulations apply.
Under proposed § 1.892-4(d)(4), if debt
is acquired before the end of the transition
period or is acquired pursuant to a binding
commitment entered into before the end
of the transition period, the existing rules
applicable before the final regulations
are published would continue to apply
to determine whether that acquisition is
commercial activity, and, accordingly,
whether income received from that debt in
future periods is derived from commercial
activity.
Because it is the acquisition of debt,
and not the mere holding of debt, that is
potentially treated as commercial activ-
ity for purposes of section 892, a debt
acquirer is not engaged in commercial
activity in taxable years following the
taxable year of the acquisition of the debt
solely by reason of holding the debt in
the subsequent taxable years. Further-
more, a debt that was acquired in a previ-
ous year and held in the current year does
not cause other debt acquisitions in the
current year to be treated as commercial
activity.
III. Applicability Date for Effective
Control Rules
Proposed § 1.892-5(e)(2)(i) would sim-
ilarly provide foreign governments with a
transition period of at least 90 days after
the publication date, or until the start of
the first taxable year after the publication
date, before the effective control rules in
the final regulations apply.
Under proposed § 1.892-5(e)(2)(ii), the
effective control rules in the final regula-
tions would not apply to a foreign govern-
ment’s existing interests in an entity unless
the foreign government acquires, after the
transition period, and excluding acquisi-
tions pursuant to a binding commitment
entered into before the end of the transi-
tion period, new interests in the entity that,
by themselves, would provide the foreign
government with effective control under
the final regulations. Unless and until this
occurs, whether that entity is a controlled
commercial entity would be determined
under the existing rules applicable before
the final regulations are published, which
will take into account all interests, regard-
less of when acquired.
Special Analyses
I. Regulatory Planning and Review –
Economic Analysis
These proposed regulations are not
subject to review under section 6(b) of
Executive Order 12866 pursuant to the
Memorandum of Agreement (July 4,
2025) between the Treasury Department
and the Office of Management and Bud-
get (OMB) regarding review of tax regu-
lations.
II. Paperwork Reduction Act
The Paperwork Reduction Act of 1995
(44 U.S.C. 3501–3520) generally requires
that a Federal agency obtain the approval
of the OMB before collecting information
from the public, whether such collection
of information is mandatory, voluntary,
or required to obtain or retain a benefit.
There are no additional information col-
lection requirements associated with these
proposed regulations.
III. Regulatory Flexibility Act
Pursuant to the Regulatory Flexibility
Act (5 U.S.C. chapter 6), it is hereby cer-
tified that this rulemaking will not have a
significant economic impact on a substan-
tial number of small entities within the
meaning of section 601(6) of the Regu-
latory Flexibility Act. This certification is
based on the fact that the proposed regula-
tions affect foreign governments, includ-
ing their controlled entities, with income
from sources within the United States.
Accordingly, the entities affected by the
proposed regulations are not considered
small entities, and a regulatory flexibility
analysis under the Regulatory Flexibility
Act is not required.

Bulletin No. 2026–25 1585 June 15, 2026
IV. Section 7805(f)
Pursuant to section 7805(f) of the
Code, these proposed regulations will be
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administra-
tion for comment on their impact on small
business.
V. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates
Reform Act of 1995 requires that agencies
assess anticipated costs and benefits and
take certain other actions before issuing a
final rule that includes any Federal man-
date that may result in expenditures in any
one year by a State, local, or Tribal gov-
ernment, in the aggregate, or by the pri-
vate sector, of $100 million in 1995 dol-
lars, updated annually for inflation. The
proposed regulations do not include any
Federal mandate that may result in expen-
ditures by State, local, or Tribal govern-
ments, or by the private sector in excess of
that threshold.
VI. Executive Order 13132: Federalism
Executive Order 13132 (entitled
“Federalism”) prohibits an agency from
publishing any rule that has federalism
implications if the rule either imposes
substantial, direct compliance costs on
State and local governments, and is not
required by statute, or preempts State law,
unless the agency meets the consultation
and funding requirements of section 6 of
the Executive order. The proposed regu-
lations do not have federalism implica-
tions and do not impose substantial direct
compliance costs on State and local gov-
ernments or preempt State law within the
meaning of the Executive order.
Comments and Requests for Public
Hearing
Before the proposed regulations are
adopted as final regulations, consideration
will be given to any comments that are
submitted timely to the IRS as prescribed
in the preamble under the ADDRESSES
heading. The Treasury Department and
the IRS request comments on all aspects
of the proposed regulations. Any com-
ments submitted will be made available
at https://www.regulations.gov or upon
request.
A public hearing will be scheduled if
requested in writing by any person who
submits electronic or written comments.
Requests for a public hearing are also
encouraged to be made electronically. If
a public hearing is scheduled, notice of
the date and time for the public hearing
will be published in the Federal Regis-
ter.
Drafting Information
The principal authors of the proposed
regulations are Jack Zhou and Peter
Merkel of the Office of Associate Chief
Counsel (International). However, other
personnel from the Treasury Department
and the IRS participated in their develop-
ment.
Partial Withdrawal of Proposed
Regulations
Under the authority of 26 U.S.C.
892(c) and 7805, proposed §§ 1.892-
4(d) and 1.892-5(e), contained in the
notice of proposed rulemaking that was
published in the Federal Register on
December 15, 2025 (90 FR 57928), are
withdrawn.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Proposed Amendments to the
Regulations
Accordingly, the Treasury Department
and the IRS propose to amend 26 CFR
part 1 as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as fol-
lows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.892-4 is amended
by:
a. Redesignating paragraph (d) as para-
graph (d)(1);
b. Revising the heading of newly redes-
ignated paragraph (d)(1); and
c. Adding paragraphs (d)(2) introduc-
tory text and (d)(3) and (4).
The revision and additions read as fol-
lows:
§ 1.892-4 Commercial activities.
* * * * *
(d) Applicability date—(1) In general.
* * *
(2) Debt acquisition applicability date.
Except as provided in paragraph (d)(3) of
this section, paragraph (c)(1) of this sec-
tion applies to acquisitions of debt on or
after the date that is the later of:
(i) The first day of the acquirer’s first
taxable year beginning on or after [DATE
OF PUBLICATION OF FINAL RULE],
or
(ii) 90 days after [DATE OF PUBLI-
CATION OF FINAL RULE].
(3) Binding commitment rule. Para-
graph (c)(1) of this section does not apply
to debt acquired pursuant to a binding
commitment entered into before the later
of the dates described in paragraphs (d)(2)
(i) and (ii) of this section.
(4) Rules for debt acquisitions and
commitments before the applicability
date. Debt acquired before the later of the
dates described in paragraphs (d)(2)(i) and
(ii) of this section or pursuant to a bind-
ing commitment described in paragraph
(d)(3) of this section shall continue to be
governed by §§ 1.892-4 and 1.892-4T, as
contained in 26 CFR in part 1 in effect on
April 1, 2026.
Par. 3. Section 1.892-5 is amended by:
a. Redesignating paragraph (e) as para-
graph (e)(1);
b. Revising the heading of newly redes-
ignated paragraph (e)(1); and
c. Adding paragraph (e)(2) introduc-
tory text.
The revision and addition read as fol-
lows:
§ 1.892-5 Controlled commercial entity.
* * * * *
(e) Applicability date—(1) In general.
* * *
(2) Effective control applicability
date—(i) In general. Except as provided
in paragraph (e)(2)(ii) of this section,
paragraph (c)(2) of this section applies to
determine whether a foreign government

June 15, 2026 1586 Bulletin No. 2026–25
has effective control of an entity on or
after the date that is the later of:
(A) The first day of the foreign gov-
ernment’s first taxable year beginning on
or after [DATE OF PUBLICATION OF
FINAL RULE], or
(B) 90 days after [DATE OF PUBLI-
CATION OF FINAL RULE].
(ii) Rules with respect to previously
acquired interests. If a foreign govern-
ment holds any previously acquired inter-
ests (as defined in paragraph (e)(2)(ii)(B)
of this section) in an entity, paragraph (c)
(2) of this section applies to determine
whether the foreign government has
effective control of the entity beginning
on the date on which the foreign gov-
ernment first acquires new controlling
interests (as defined in paragraph (e)(2)
(ii)(A) of this section) in the entity. Until
the date that the foreign government first
acquires new controlling interests in the
entity, all of the foreign government’s
interests in that entity shall continue to
be governed by §§ 1.892-5 and 1.892-5T,
as contained in 26 CFR in part 1 in effect
on April 1, 2026.
(A) New controlling interests. For pur-
poses of this paragraph (e)(2)(ii), the term
new controlling interests means one or
more interests in an entity, other than any
previously acquired interests (as defined
in paragraph (e)(2)(ii)(B) of this section),
that in the aggregate result in effective
control of the entity under paragraph (c)
(2) of this section.
(B) Previously acquired interests. For
purposes of this paragraph (e)(2)(ii), the
term previously acquired interests means
one or more interests in an entity acquired
by a foreign government before the later
of the dates described in paragraphs (e)(2)
(i)(A) and (B) of this section, or acquired
pursuant to a binding commitment entered
into before the later of such dates.
Frank J. Bisignano,
Chief Executive Officer.
(Filed by the Office of the Federal Register May 29,
2026, 8:45 a.m., and published in the issue of the
Federal Register for June 01, 2026, 91 FR 32366)

Bulletin No. 2026–25 i June 15, 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 pub-
lished 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished 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 pub-
lished ruling that is not considered deter-
minative 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 sub-
stance 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 rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings 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.
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.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

June 15, 2026 ii Bulletin No. 2026–25
Numerical Finding List
1
Bulletin 2026–25
Announcements:
2026-1, 2026-04 I.R.B. 402
2026-2, 2026-05 I.R.B. 447
2026-3, 2026-06 I.R.B. 518
2026-4, 2026-06 I.R.B. 533
2026-5, 2026-07 I.R.B. 540
2026-6, 2026-10 I.R.B. 634
2026-7, 2026-11 I.R.B. 697
2026-8, 2026-16 I.R.B. 813
2026-9, 2026-18 I.R.B. 881
2026-10, 2026-23 I.R.B. 1569
AOD:
2026-1, 2026-23 I.R.B. 1556
Notices:
2026-2, 2026-02 I.R.B. 304
2026-3, 2026-02 I.R.B. 307
2026-5, 2026-02 I.R.B. 309
2026-6, 2026-02 I.R.B. 313
2026-1, 2026-04 I.R.B. 365
2026-8, 2026-04 I.R.B. 368
2026-10, 2026-04 I.R.B. 378
2026-11, 2026-06 I.R.B. 491
2026-12, 2026-06 I.R.B. 496
2026-13, 2026-06 I.R.B. 499
2026-9, 2026-07 I.R.B. 534
2026-7, 2026-11 I.R.B. 637
2026-14, 2026-11 I.R.B. 654
2026-15, 2026-11 I.R.B. 658
2026-16, 2026-11 I.R.B. 685
2026-17, 2026-12 I.R.B. 698
2026-4, 2026-13 I.R.B. 726
2026-19, 2026-15 I.R.B. 797
2026-20, 2026-15 I.R.B. 800
2026-22, 2026-15 I.R.B. 802
2026-23, 2026-15 I.R.B. 804
2026-24, 2026-17 I.R.B. 835
2026-25, 2026-17 I.R.B. 836
2026-26, 2026-18 I.R.B. 878
2026-27, 2026-21 I.R.B. 1502
2026-29, 2026-22 I.R.B. 1537
2026-30, 2026-22 I.R.B. 1538
2026-31, 2026-23 I.R.B. 1562
2026-34, 2026-23 I.R.B. 1565
2026-33, 2026-24 I.R.B. 1572
2026-32, 2026-25 I.R.B. 1578
2026-35, 2026-25 I.R.B. 1580
Proposed Regulations:
REG-101952-24, 2026-03 I.R.B. 345
REG-110519-25, 2026-03 I.R.B. 353
Proposed Regulations:—Continued
REG-132251-11; REG-134219-08,
2026-03 I.R.B. 358
REG-103430-24, 2026-05 I.R.B. 447
REG-112829-25, 2026-05 I.R.B. 452
REG-113515-25, 2026-05 I.R.B. 455
REG-121244-23, 2026-09 I.R.B. 579
REG-105064-25, 2026-13 I.R.B. 735
REG-108921-25, 2026-13 I.R.B. 756
REG-117002-25, 2026-13 I.R.B. 761
REG-117270-25, 2026-13 I.R.B. 772
REG-117298-21, 2026-14 I.R.B. 784
REG-114499-25, 2026-18 I.R.B. 883
REG-113229-25, 2026-19 I.R.B. 900
REG-108706-25, 2026-21 I.R.B. 1508
REG-119294-25, 2026-21 I.R.B. 1509
CC-00349656-26, 2026-25 I.R.B. 1583
Revenue Procedures:
2026-1, 2026-01 I.R.B. 1
2026-2, 2026-01 I.R.B. 119
2026-3, 2026-01 I.R.B. 143
2026-4, 2026-01 I.R.B. 160
2026-5, 2026-01 I.R.B. 258
2026-6, 2026-02 I.R.B. 314
2026-7, 2026-02 I.R.B. 316
2026-8, 2026-04 I.R.B. 380
2026-9, 2026-04 I.R.B. 393
2026-10, 2026-04 I.R.B. 394
2026-12, 2026-07 I.R.B. 535
2026-13, 2026-09 I.R.B. 563
2026-11, 2026-12 I.R.B. 707
2026-15, 2026-13 I.R.B. 729
2026-16, 2026-13 I.R.B. 733
2026-17, 2026-15 I.R.B. 805
2026-19, 2026-19 I.R.B. 899
2026-14, 2026-20 I.R.B. 910
2026-21, 2026-22 I.R.B. 1538
2026-22, 2026-22 I.R.B. 1541
2026-23, 2026-22 I.R.B. 1542
2026-24, 2026-25 I.R.B. 1582
Revenue Rulings:
2026-1, 2026-02 I.R.B. 299
2026-2, 2026-03 I.R.B. 342
2026-3, 2026-06 I.R.B. 485
2026-4, 2026-06 I.R.B. 487
2026-5, 2026-08 I.R.B. 542
2026-6, 2026-11 I.R.B. 635
2026-7, 2026-15 I.R.B. 791
2026-8, 2026-16 I.R.B. 812
2026-9, 2026-19 I.R.B. 897
2026-10, 2026-22 I.R.B. 1515
2026-11, 2026-24 I.R.B. 1570
Treasury Decisions:
10042, 2026-03 I.R.B. 320
10041, 2026-04 I.R.B. 360
10039, 2026-05 I.R.B. 403
10040, 2026-05 I.R.B. 416
10043, 2026-15 I.R.B. 793
10044, 2026-18 I.R.B. 840
10045, 2026-21 I.R.B. 1491
10047, 2026-21 I.R.B. 1494
10046, 2026-22 I.R.B. 1512
10048, 2026-23 I.R.B. 1558
1
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.

Bulletin No. 2026–25 iii June 15, 2026
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2026–25
1
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.

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