Internal Revenue Bulletin 2026-19 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2026–19
May 4, 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
REG-113229-25, page 900.
This document contains proposed amendments relating to
the dollar thresholds in regulations governing information
reporting for payments made in the course of a trade or busi-
ness and the corresponding backup withholding regulations.
This document also contains proposed amendments to the
regulations governing wagering losses. The proposed reg-
ulations reflect recent changes to the statutory law. These
changes will affect persons who make payments in the
course of their trade or business and those persons claiming
a deduction for wagering losses.
INCOME TAX
Rev. Proc. 2026-19, page 899.
Revenue Procedure 2026-19 provides domestic asset/lia-
bility percentages and domestic investment yields needed
by foreign life insurance companies and foreign property
and liability insurance companies to compute their minimum
effectively connected net investment income under section
842(b) of the Internal Revenue Code for taxable years begin-
ning after December 31, 2024.
Rev. Rul. 2026-9, page 897.
Federal rates; adjusted federal rates; adjusted federal long-
term rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for May 2026.
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.
May 4, 2026 Bulletin No. 2026–19

Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7702, 7872.)
Rev. Rul. 2026-9
This revenue ruling provides vari-
ous prescribed rates for federal income
tax purposes for May 2026 (the current
month). Table 1 contains the short-
term, mid-term, and long-term applica-
ble federal rates (AFR) for the current
month for purposes of section 1274(d)
of the Internal Revenue Code. Table 2
contains the short-term, mid-term, and
long-term adjusted applicable federal
rates (adjusted AFR) for the current
month for purposes of section 1288(b).
Table 3 sets forth the adjusted fed-
eral long-term rate and the long-term
tax-exempt rate described in section
382(f). Table 4 contains the appropri-
ate percentages for determining the
low-income housing credit described in
section 42(b)(1) for buildings placed in
service during the current month. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized new buildings placed in service
after July 30, 2008, shall not be less
than 9%. Finally, Table 5 contains the
federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.
REV. RUL. 2026-9 TABLE 1
Applicable Federal Rates (AFR) for May 2026
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR3.82%3.78%3.76%3.75%
110% AFR4.20%4.16%4.14%4.12%
120% AFR4.59%4.54%4.51%4.50%
130% AFR4.97%4.91%4.88%4.86%
Mid-term
AFR4.08%4.04%4.02%4.01%
110% AFR 4.49%4.44%4.42%4.40%
120% AFR4.91%4.85%4.82%4.80%
130% AFR5.32%5.25%5.22%5.19%
150% AFR6.15%6.06%6.01%5.98%
175% AFR7.19%7.07%7.01%6.97%
Long-term
AFR4.83%4.77%4.74%4.72%
110% AFR5.32%5.25%5.22%5.19%
120% AFR5.80%5.72%5.68%5.65%
130% AFR6.30%6.20%6.15%6.12%
REV. RUL. 2026-9 TABLE 2
Adjusted AFR for May 2026
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR2.89%2.87%2.86%2.85%
Mid-term adjusted AFR3.09%3.07%3.06%3.05%
Long-term adjusted AFR3.65%3.62%3.60%3.59%
Bulletin No. 2026–19 897 May 4, 2026

REV. RUL. 2026-9 TABLE 3
Rates Under Section 382 for May 2026
Adjusted federal long-term rate for the current month3.65%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)
3.65%
REV. RUL. 2026-9 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for May 2026
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit8.04%
Appropriate percentage for the 30% present value low-income housing credit 3.44%
REV. RUL. 2026-9 TABLE 5
Rate Under Section 7520 for May 2026
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
5.00%

Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of May 2026. See Rev.
Rul. 2026-9, page 897.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of May 2026. See Rev. Rul.
2026-9, page 897.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2026. See Rev. Rul. 2026-9, page 897.
Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of May 2026. See Rev. Rul.
2026-9, page 897.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2026. See Rev. Rul. 2026-9, page 897.

May 4, 2026 898 Bulletin No. 2026–19

Bulletin No. 2026–19 899 May 4, 2026
Part III
26 CFR 601.105: Examination of returns and claims
for refund; credit or abatement; determination of tax
liability
(Also: 842(b))
Rev. Proc. 2026-19
SECTION 1. PURPOSE
This revenue procedure provides the
domestic asset/liability percentages and
domestic investment yields needed by
foreign life insurance companies and for-
eign property and liability insurance com-
panies to compute their minimum effec-
tively connected net investment income
under section 842(b) of the Internal Rev-
enue Code for taxable years beginning
after December 31, 2024. Instructions are
provided for computing foreign insurance
companies’ liabilities for the estimated tax
and installment payments of estimated tax
for taxable years beginning after Decem-
ber 31, 2024. For more specific guidance
regarding the computation of the amount
of net investment income to be included
by a foreign insurance company on its
U.S. income tax return, see Notice 89-96,
1989-2 C.B. 417. For the domestic asset/
liability percentage and domestic invest-
ment yield, as well as instructions for
computing foreign insurance companies’
liabilities for estimated tax and install-
ment payments of estimated tax for tax-
able years beginning after December 31,
2023, see Rev. Proc. 2025-20, 2025-22
I.R.B. 1448.
SECTION 2. PERCENTAGES AND
YIELDS
.01 DOMESTIC ASSET/LIABILITY
PERCENTAGES FOR 2025. The Secre-
tary determines the domestic asset/liabil-
ity percentage separately for life insur-
ance companies and property and liability
insurance companies. For the first taxable
year beginning after December 31, 2024,
the relevant domestic asset/liability per-
centages are:
128.2 percent for foreign life insurance
companies, and
202.4 percent for foreign property and
liability insurance companies.
.02 DOMESTIC INVESTMENT
YIELDS FOR 2025. The Secretary is
required to prescribe separate domestic
investment yields for foreign life insur-
ance companies and for foreign property
and liability insurance companies. For the
first taxable year beginning after Decem-
ber 31, 2024, the relevant domestic invest-
ment yields are:
2.1 percent for foreign life insurance
companies, and
2.2 percent for foreign property and
liability insurance companies.
.03 SOURCE OF DATA FOR 2025.
The section 842(b) percentages to be used
for the 2025 taxable year are based on tax
return data from the 2023 taxable year.
SECTION 3. ESTIMATED TAXES
To compute estimated tax and the
installment payments of estimated tax
due for taxable years beginning after
December 31, 2024, a foreign insurance
company must compute its estimated
tax payments by adding to its income
other than net investment income the
greater of (i) its net investment income
as determined under section 842(b)(5)
that is actually effectively connected
with the conduct of a trade or business
within the United States for the rele-
vant period, or (ii) the minimum effec-
tively connected net investment income
under section 842(b) that would result
from using the most recently available
domestic asset/liability percentage and
domestic investment yield. Thus, for
installment payments due after the pub-
lication of this revenue procedure, the
domestic asset/liability percentages
and the domestic investment yields
provided in this revenue procedure
must be used to compute the minimum
effectively connected net investment
income. However, if the due date of an
installment is less than 20 days after the
date this revenue procedure is published
in the Internal Revenue Bulletin, the
asset/liability percentages and domes-
tic investment yields provided in Rev.
Proc. 2025-20 may be used to compute
the minimum effectively connected net
investment income for such installment.
For further guidance in computing esti-
mated tax, see Notice 89-96.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December
31, 2024.
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Sheila Ramaswamy of the
Office of Associate Chief Counsel (Inter-
national). For further information regard-
ing this revenue procedure contact Sheila
Ramaswamy at (202) 317-6938 (not a toll
free call).

May 4, 2026 900 Bulletin No. 2026–19
Part IV
Notice of Proposed
Rulemaking
Increase in Threshold for
Requiring Information
Reporting with Respect to
Certain Payees; Extension
and Modification of
Limitation on Wagering
Losses
REG-113229-25
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing.
SUMMARY: This document contains
proposed amendments relating to the dol-
lar thresholds in regulations governing
information reporting for payments made
in the course of a trade or business and
the corresponding backup withholding
regulations. This document also contains
proposed amendments to the regulations
governing wagering losses. The proposed
regulations reflect recent changes to the
statutory law. These changes will affect
persons who make payments in the course
of their trade or business and those per-
sons claiming a deduction for wagering
losses.
DATES: Electronic or written comments
and requests for a public hearing must be
received by June 16, 2026.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic submis-
sions via the Federal eRulemaking Portal
at https://www.regulations.gov (indicate
IRS and REG-113229-25) by follow-
ing the online instructions for submit-
ting comments. As required by 5 U.S.C.
553(b)(4), a plain language summary of
the proposed rule is also available on the
Federal eRulemaking Portal. Requests for
a public hearing must be submitted as pre-
scribed in the “Comments and Requests
for a Public Hearing” section. Once sub-
mitted to the Federal eRulemaking Portal,
comments cannot be edited or withdrawn.
The Department of the Treasury (Treasury
Department) and the IRS will publish for
public availability any comment submit-
ted to the IRS’s public docket. Send paper
submissions to: CC:PA:01:PR (REG-
113229-25), room 5503, Internal Revenue
Service, P.O. Box 7604, Ben Franklin Sta-
tion, Washington, DC 20044.
FOR FURTHER INFORMATION
CONTACT: Concerning the proposed
regulations, William Prater at (202) 317-
6845 (not toll-free number); concerning
submissions of comments or requests for a
hearing, the Publications and Regulations
Section at (202) 317-6901 (not toll-free
number) or by email at publichearings@
irs.gov (preferred).
SUPPLEMENTARY INFORMATION:
Authority
This document contains proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1) under sections 165,
6041, and 6041A of the Internal Revenue
Code (Code) and the Employment Taxes
and Collection of Income Tax at Source
Regulations (26 CFR part 31) under sec-
tion 3406 of the Code. The proposed reg-
ulations are issued under the authority of
sections 6041(a) and 6041A(a), which
provide the Secretary of the Treasury or
the Secretary’s delegate (Secretary) with
authority to prescribe regulations to carry
out sections 6041 and 6041A. The pro-
posed regulations are also issued under
the authority conferred by section 3406
and 3406(i), which provides the Secretary
with authority to prescribe such regula-
tions as may be necessary or appropriate
to carry out the purposes of section 3406.
Additionally, these proposed regu-
lations are issued pursuant to section
7805(a) of the Code, which authorizes the
Secretary to “prescribe all needful rules
and regulations for the enforcement of
[the Code], including all rules and regu-
lations as may be necessary by reason of
any alteration of law in relation to internal
revenue.”
Background
This document contains proposed
amendments to regulations impacted by
amendments to the Code made by sections
70114 and 70433 of Public Law 119-21,
139 Stat. 72 (July 4, 2025), commonly
known as the One, Big, Beautiful Bill Act
(OBBBA).
I. Section 165
Section 165(a) provides an itemized
deduction for losses sustained during the
taxable year that are not otherwise com-
pensated for by insurance or otherwise.
Section 165(d) limits the deduction avail-
able for losses from wagering transac-
tions, including any deduction otherwise
allowable that is incurred in carrying on
wagering transactions.
Prior to the changes made by the
OBBBA, section 165(d) limited losses
from wagering transactions to the extent
of the gains from such transactions. Cur-
rent §1.165-10 restates this limitation and
provides a rule for the treatment of wager-
ing losses on a joint return.
OBBBA section 70114(a) amended
section 165(d) to limit this deduction to
90 percent of the amount of wagering
losses during a taxable year and only to
the extent of gains from wagering transac-
tions during a taxable year.
II. Section 6041
Section 6041(a) requires persons
engaged in a trade or business to file
information returns reporting payments
of fixed or determinable gains, prof-
its, and income equal to, or in excess
of, a particular dollar threshold made to
another person in the course of that trade
or business. Prior to the enactment of the
OBBBA, this dollar threshold was $600.
OBBBA section 70433(a) increased the
$600 threshold in section 6041 to a base
threshold of $2,000 for payments made
after December 31, 2025. Additionally,
OBBBA section 70433(b) added section

Bulletin No. 2026–19 901 May 4, 2026
6041(h), which provides that, for calendar
years after 2026, this base threshold will
be indexed to inflation. Lastly, OBBBA
section 70433(e)(1) and (2) amended sec-
tion 6041 by amending the section head-
ing from “$600 or More” to “Exceeding
Threshold” and changing the phrase “tax-
able year” to “calendar year.” Pursuant to
OBBBA section 70433(f), these changes
are effective for payments made after
December 31, 2025.
Several existing regulations promul-
gated under section 6041 reference the
prior $600 threshold amount in their text.
However, §1.6041-10, which was pub-
lished in the Federal Register (TD 9807,
81 FR 96374) on December 30, 2016,
contains a $1,200 reporting threshold for
winnings from bingo and slot machine
play and a $1,500 reporting threshold for
winnings from keno.
III. Section 6041A
Section 6041A(a) requires persons
engaged in a trade or business to file
information returns reporting payments
of remuneration for services made in
the course of that trade or business that
equal or exceed a dollar threshold. Prior
to the enactment of the OBBBA, this dol-
lar threshold was $600. OBBBA section
70433(c) amended the $600 threshold in
section 6041A(a)(2) to cross-reference
“the dollar amount in effect for such cal-
endar year under section 6041(a).” Pur-
suant to OBBBA section 70433(f), this
change is effective for payments made
after December 31, 2025.
IV. Section 3406
Section 3406(a)(1) requires backup
withholding for reportable payments
if certain conditions are met. Sections
3406(b)(1)(B), (b)(3)(A), and (b)(3)(B)
provide that payments required to be
shown on a return under sections 6041
and 6041A are reportable payments. Sec-
tion 3406(b)(4) provides that, generally,
whether a payment is reportable is deter-
mined without regard to the minimum
amount that must be paid before a return
is required. However, pursuant to section
3406(b)(6)(A) payments described in sec-
tions 6041 and 6041A were only treated as
reportable payments for backup withhold-
ing if the aggregate amount of payments
to a payee in the calendar year equaled or
exceeded $600.
OBBBA section 70433(d)(1) amended
the $600 threshold in section 3406(b)(6)
(A) to cross reference “the dollar amount
in effect for such calendar year under sec-
tion 6041(a).” In addition, OBBBA sec-
tion 70433(d)(2) amended the reference to
“$600 or More” in the heading of section
3406(b)(6) to say “Only Where in Excess
of Threshold.” These changes are effec-
tive for payments made after December
31, 2025.
Explanation of Provisions
I. Limitation on Deduction for Wagering
Losses
Following the enactment of OBBBA
section 70114(a), the first sentence of
§1.165-10, providing that losses from
wagering transactions are limited to the
extent of gains from such transactions,
no longer accurately describes the lim-
itations on wagering losses in section
165(d). The proposed regulations would
amend this sentence to limit the deduction
to 90 percent of the amount of wagering
losses during a taxable year and only to
the extent of gains from wagering transac-
tions during a taxable year. The proposed
regulations would also make correspond-
ing changes to the treatment of combined
losses of spouses from wagering transac-
tions to reflect the changes made by the
OBBBA.
II. Thresholds for Payments Reported
under Sections 6041 and 6041A
The proposed regulations would also
update the regulations under sections
6041, 6041A, and 3406 to change the ref-
erences to the pre-OBBBA $600 thresh-
old. Consistent with the wording of the
OBBBA, these references (specifically, in
§§1.6041-1, 1.6041-2, 1.6041-7, 1.6041A-
1, 31.3406(b)(3)-1, and 31.3406(g)-2)
would be replaced with a reference to an
amount equaling or exceeding the dollar
threshold in effect for the calendar year
under section 6041(a) and (h). The ref-
erences in the proposed regulations have
non-substantive variations in the wording,
for readability.
Proposed §1.6041-1(a)(3) would define
the dollar amount in effect for the calendar
year under section 6041(a) as $2,000 for
calendar year 2026, adjusted for inflation
in subsequent calendar years as provided
in section 6041(h). Proposed §1.6041-1(a)
(1)(iv) also contains non-substantive revi-
sions to improve readability.
Because the dollar thresholds for
reporting winnings from bingo, keno,
and slot machine play provided in cur-
rent §1.6041-10(b)(2)(i) are below the
threshold established in the OBBBA, the
proposed regulations would update those
thresholds to match the new statutory
threshold in section 6041(a) as revised
by Congress. Accordingly, the proposed
regulations would modify §1.6041-10 to
provide that the threshold for reporting
payments of winnings from bingo, keno,
and slot machine play is $2,000 for cal-
endar year 2026, adjusted for inflation in
subsequent calendar years as provided in
section 6041(h). The existing limitations
related to the amount wagered in each of
the affected games would be maintained
under the proposed regulations.
Proposed Applicability Date
Section 1.165-10 is proposed to
apply to taxable years beginning after
December 31, 2025. Sections 1.6041-1,
1.6041-2, 1.6041-7, 1.6041-10 1.6041A-
1, 31.3406(b)(3)-1, and 31.3406(g)-2 are
proposed to apply to payments made on or
after January 1, 2026.
Special Analyses
I. Regulatory Planning and Review –
Economic Analysis
Executive Orders 12866 and 13563
direct agencies to assess costs and ben-
efits of available regulatory alternatives
and, if regulation is necessary, to select
regulatory approaches that maximize net
benefits (including potential economic,
environmental, public health and safety
effects, distributive impacts, and equity).
Executive Order 13563 emphasizes the
importance of quantifying both costs
and benefits, reducing costs, harmoniz-
ing rules, and promoting flexibility. This
rule is expected to be an Executive Order
14192 deregulatory action.

May 4, 2026 902 Bulletin No. 2026–19
These proposed regulations have been
designated by the Office of Management
and Budget’s (OMB’s) Office of Infor-
mation and Regulatory Affairs (OIRA) as
subject to review under Executive Order
12866 pursuant to the Memorandum of
Agreement (MOA, July 4, 2025) between
the Treasury Department and the OMB
regarding review of tax regulations. OIRA
has determined that these proposed regu-
lations are economically significant and
subject to review under section 3(f) of
Executive Order 12866 and section 1(c)
of the MOA. Accordingly, the proposed
regulations have been reviewed by OMB.
A. Background, Statute, and Proposed
Regulations
Under section 6041 of the Internal
Revenue Code (Code), persons engaged
in a trade or business that make certain
payments in the course of their trade or
business (payors) must file an information
return with the Internal Revenue Service
(IRS) to report such payments. The return
contains information about the payment;
the name of the payment recipient (payee);
and the address of the payee; and provides
the IRS with a third-party verification
of income that the payee may report on
their Federal income tax return. Similarly,
under section 6041A, persons engaged in
a trade or business that make payments
in the course of that trade or business as
remuneration for services must file infor-
mation returns to report those payments.
Under section 3406 of the Code, when
certain conditions are met, reportable pay-
ments under sections 6041 or 6041A may
be subject to backup withholding, wherein
the payor withholds a specified percentage
of the payment and remits that amount
to the IRS. Backup withholding ensures
that Federal income tax is paid on a pay-
ment that the payee might otherwise fail
to report. In addition, when payors with-
hold amounts from payments subject to
backup withholding, they are required to
file an annual return to report the amounts
withheld during the year. That same return
is also used by payors to report Federal
income tax withheld from other nonpay-
roll payments, such as pensions, annuities,
gambling winnings, etc.
Under sections 6041 and 6041A, an
information return is required to be sub-
mitted to the IRS only when the aggre-
gate dollar amount of payments made to
a payee over a reportable period equals
or exceeds the statutory threshold in sec-
tion 6041(a). Under section 3406, backup
withholding, when certain conditions are
met, is also generally required only when
the aggregate dollar amount of payments
made to a payee over the reportable period
equals or exceeds the threshold described
in section 6041(a). These statutory dol-
lar thresholds apply to certain payments
reported on four information returns—
Form 1099-MISC (Miscellaneous Infor-
mation), Form 1099-NEC (Nonemployee
Compensation), Form W-2 (Wage and
Tax Statement), and Form W-2G (Cer-
tain Gambling Winnings)—as well as
backup withholding with respect to these
payments reported on Form 945 (Annual
Return of Withheld Federal Income Tax),
as affected by the enactment of Public
Law 119-21, 139 Stat. 72 (July 4, 2025),
commonly known as the One, Big, Beau-
tiful Bill Act (OBBBA).
The OBBBA increased the statutory
threshold in section 6041(a) to a base
threshold of $2,000 for payments made
after December 31, 2025, and indexed
the threshold for inflation for calendar
years after 2026. Prior to the enactment
of the OBBBA, the dollar threshold for
reporting certain payments on Form 1099-
MISC, Form 1099-NEC, and Form W-2
was $600. This reporting level had been
in place since 1954 and had not been
indexed to inflation. Information reporting
on gambling winnings reported on Form
W-2G was governed by the same statutory
threshold, but regulations under section
6041 provided that the dollar threshold
was $1,200 for a single winning from
bingo and slot machine play and $1,500
for a single winning from keno. The stat-
utory amendments made by the OBBBA
change the dollar thresholds for all of
these payments to be $2,000 in a calendar
year for payments made after December
31, 2025, with an adjustment for inflation
in calendar years after 2026. The proposed
regulations would conform the language
in the regulations to match the new stat-
utory threshold, including the regulatory
thresholds for reporting winnings from
keno, bingo, and slot machine play.
The OBBBA also modified the rules
governing the itemized deduction for
losses from wagering transactions under
section 165(d) of the Code. Prior to the
statutory change in the OBBBA, such
deduction was limited to the extent of the
gains from wagering transactions during
a taxable year (reported as income else-
where on the tax return). The OBBBA
amended the deduction to be 90 percent of
the amount of wagering losses, up to the
extent of gains from wagering transactions
during the taxable year. The proposed reg-
ulations would modify the existing regula-
tions to reflect this statutory change.
B. Need for Regulation
The proposed amendments ensure that
the regulations reflect current law, thereby
preventing confusion by individuals and
entities who are impacted by the updates
to the relevant statutory provisions.
C. Economic Analysis
1. Baseline
The Treasury Department and the IRS
have assessed the benefits and costs of the
proposed regulations relative to a no-ac-
tion baseline reflecting anticipated Fed-
eral income tax-related behavior in the
absence of the proposed regulations.
2. Economic Effects of the Proposed
Regulations
a. Reporting and backup withholding
threshold
The proposed amendments revise the
existing regulations to reflect the afore-
mentioned statutory changes made by
the OBBBA. In addition to the proposed
regulations, the IRS may publish sub-reg-
ulatory and informal guidance, such as
notices, announcements, publications
on form instructions, website materials,
etc., to instruct taxpayers about how to
interpret and apply the new statutory lan-
guage to their situations. Published draft
Publication 1099, General Instructions
for Certain Information Returns, for Tax
Year 2026 already contains references
to the statutory changes to the reporting
threshold made by the OBBBA. Because
the interpretation and application of the
newly enacted statutory language is likely

Bulletin No. 2026–19 903 May 4, 2026
to have no ambiguity, the sub-regulatory
and informal guidance will likely provide
sufficient guidance for taxpayers, and
the benefits of the proposed regulations
beyond such guidance may be limited.
Failure to update now-outdated reg-
ulations after law changes could create
confusion and uncertainty for taxpayers
impacted by the statutory changes. Tax-
payers and practitioners who normally rely
on the existing regulations must turn to
other sources to learn about how to apply
the statutory changes to their situations or
else use their own interpretations. In cases
of interpretive uncertainty, taxpayers and
practitioners would incur additional com-
pliance costs as they try to understand
how to apply accurately the new statutory
requirements. Some taxpayers and prac-
titioners may apply the lower, outdated
thresholds in the regulations despite the
new, higher thresholds in the statutes. This
is especially true for payors of winnings
from keno, bingo, and slot machine play,
which have historically followed a regula-
tory exception to the statutory threshold.
For payors, the enacted higher dollar
threshold eliminates the reporting and
backup withholding requirements on
affected payments between the old and
new thresholds. This change will reduce
the compliance costs incurred by these
payors to report payments and with-
hold taxes. Because this is a change in
the statute, these dollar thresholds apply
regardless of these proposed regulations.
However, because payors may follow the
existing regulations, failing to update the
regulations to reflect the changes in the
statute increases the likelihood that payors
will not take full advantage of the burden
reductions associated with the lessened
reporting and withholding requirements.
The dollar thresholds specified in the
existing regulations for reporting win-
nings from keno, bingo, and slot machine
play are above the pre-OBBBA statutory
level of $600 and below the $2,000 level
in current law. Because the new statutory
level exceeds the pre-OBBBA regulatory
reporting thresholds for these games, the
proposed regulations amend these thresh-
olds to match the new statutory level of
$2,000. In the absence of the proposed
regulations, the new dollar threshold of
$2,000 would still apply for reporting win-
nings from keno, bingo, and slot machine
play. Updating the regulations would
provide clear and consistent guidance to
taxpayers with respect to the increased
reporting threshold.
Because the proposed regulations only
modify the existing regulations to com-
port with the new statutory thresholds, the
discretionary effects of the proposed reg-
ulations hinge on the extent to which they
eliminate interpretive ambiguity and infor-
mational inconsistency and, as a result,
facilitate application of the new statutory
law by affected taxpayers and entities.
Persons engaged in a trade or business
are no longer required to report to the IRS
certain payments below $2,000, effective
for payments made in calendar year 2026.
The Treasury Department and IRS esti-
mate that, for tax year 2024, more than
328,000 payors filed 7.9 million Forms
1099-MISC reporting affected payments
of at least $600 and less than $2,000, and
approximately 3.3 million payors filed
18.8 million Forms 1099-NEC reporting
payments of non-employee compensation
of at least $600 and less than $2,000. For
the same tax year, more than 4,000 payors
filed 17.3 million Forms W-2G reporting
gambling winnings in the range between
the old and new reporting thresholds,
almost 80 percent of which were for win-
nings from slot machine play. These pay-
ors also filed Forms 945 to report Federal
income tax they withheld on the report-
able payments, when certain conditions
are met. In addition, for tax year 2024
approximately 32,000 employers filed 0.9
million W-2s with paid wages of at least
$600 and less than $2,000 that were not
subject to withholding for social security,
Medicare, or federal income taxes. This
situation applies in a narrow set of circum-
stances where withholding for social secu-
rity and Medicare taxes is not required,
such as for cases of foreign agricultural
workers, election workers, and certain
members of the clergy.
In total, 3.5 million payors filed infor-
mation returns for tax year 2024 that were
between the old and new filing thresholds.
This estimate counts a payor only once
if they are in the affected range for more
than one type of return. After adjusting for
an expected growth rate to tax year 2026,
the Treasury Department and the IRS esti-
mate that 3.6 million payors are poten-
tially affected by the statutory change and
the clarity provided by these proposed
regulations. The Treasury Department
and IRS expect that most of these affected
payors will only file information returns
that are above the new threshold provided
by OBBBA, without needing clarification
from the proposed regulations. However,
the proposed regulations will provide
clarity and save some affected payors time
and resources to identify the appropriate
filing threshold.
For the projected reductions in compli-
ance burdens associated with filing these
returns as a result of the higher reporting
thresholds established in the OBBBA,
please refer to the Paperwork Reduction
Act section of this document found in Part
II of this Special Analyses.
b. Treatment of wagering losses
The statutory change in the percentage
of wagering losses that may be deducted
from 100 percent to 90 percent reduces
the expected after-tax return to wagering
transactions for taxpayers who claim an
itemized deduction for wagering losses.
For taxpayers who do not itemize deduc-
tions no deduction may be claimed for
wagering losses. Most taxpayers that
report gains from wagering transactions
do not itemize deductions and would be
unaffected by the statutory change. For
tax year 2022, the Treasury Department
and IRS estimate that about 2.3 million
taxpayers reported gains from wagering
transactions on individual tax returns,
but less than a third of these taxpayers,
approximately 670,000, also claim an
itemized deduction for wagering losses.
The Treasury Department and the IRS
project a total of 673,000 taxpayers will
take an itemized deduction for wagering
losses for tax year 2026. The relatively
small share of taxpayers that report an
itemized deduction for wagering losses is
consistent with the small share of taxpay-
ers overall that itemize deductions. The
Treasury Department and the IRS estimate
that 15 percent or fewer taxpayers itemize
under current law.
The proposed regulations provide
clarity regarding how to report wager-
ing losses on a tax return and certainty
to affected taxpayers about the expected
after-tax return on wagering transactions.
However, it is expected that tax soft-

May 4, 2026 904 Bulletin No. 2026–19
ware companies and tax professionals
will update their products and services to
reflect the law change even in the absence
of updated regulations. The Treasury
Department estimates that, of the more
than 161 million individual income tax
returns filed for tax year 2022, nearly 98
percent used assistance from a preparer
or tax software while less than 3 percent
were self-prepared paper returns filed by
taxpayers without software assistance,
likely following IRS instructions on tax
forms. For these reasons, although updat-
ing the existing regulations helps reduce
interpretive ambiguity and informational
inconsistency, the economic impacts of
any discretionary aspects of the proposed
regulations relating to the deduction of
wagering losses are likely minimal.
3. Summary
Based on the available models and
data, the Treasury Department and the
IRS estimate that the economic costs and
benefits of the proposed regulations would
be small. The Treasury Department and
the IRS invite public comments and addi-
tional data on the economic effects that
would result from these proposed regula-
tions.
II. 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 OMB before collecting
information from the public, whether that
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.
The collections of information in
the proposed regulations with respect
to sections 6041 and 6041A are in pro-
posed §§1.6041-1 and 1.6041A-1. The
likely respondents are persons who make
payments in the course of their trade
or business. For purposes of the PRA,
the reporting burden associated with
the collection of information in pro-
posed §§1.6041-1 and 1.6041A-1 will
be reflected in the Paperwork Reduction
Act Submissions associated with Forms
1099-MISC, 1099-NEC, W-2, and W-2G
(OMB control numbers 1545-0115,
1545-0116, 1545-0029, and 1545-0238,
respectively). The collection of infor-
mation in the proposed regulations with
respect to section 3406 is in proposed
§§31.3406(b)(3)-1 and 31.3406(g)-2.
The collected information would be used
by the payor to determine whether pay-
ments to the payee exceed a threshold
that would require backup withholding
and the issuance of an information return.
The burden for these requirements is
included with the Form and Instructions
for Form 945, Annual Return of Withheld
Federal Income Tax. The Form 945 and
Instructions for Form 945 are approved
under OMB control number 1545-0029.
The higher reporting threshold set by
OBBBA leads to a significant reduction
in the expected number of Forms 1099-
MISC, 1099-NEC, W-2G, and to a lesser
extent, Forms W-2 and 945, that will
need to be filed. For calendar year 2027,
reflecting tax year 2026 returns, the Trea-
sury Department and the IRS estimate that
the higher reporting threshold will result
in an overall reduction in filing burden of
$982 million in 2024 dollars as described
below and summarized in the accompany-
ing table.
Prior to the passage of the OBBBA,
the IRS projected that 42.60 million Form
1099-MISCs would be filed in calen-
dar year 2027 (see IRS Publication 6961
(Rev. 9-2025)). The Treasury Department
and the IRS estimate that 9.32 million of
these forms would have payments in the
range affected by the change in the filing
threshold and would no longer need to be
filed. Multiplying the reduction in 9.32
million forms filed by the 0.41 hours per
form time burden yields a decrease of 3.82
million burden hours and then multiplying
by the $58.40 per hour monetization rate
(in 2024 dollars) provides an expected
reduction in filing burden of $223 million.
Similarly, prior to the passage of the
OBBBA, the IRS projected that 62.72 mil-
lion Form 1099-NECs would be filed in
calendar year 2027. The Treasury Depart-
ment and the IRS estimate that 19.54
million of these forms would have pay-
ments affected by the change in the filing
threshold and would no longer need to be
filed. Multiplying the reduction in 19.54
million forms filed by the 0.25 hours per
form time burden yields a decrease of 4.89
million burden hours and then multiplying
by the $58.40 per hour monetization rate
provides an expected reduction in filing
burden of $285 million.
In addition, prior to the passage of the
OBBBA, the IRS projected that 267.82
million Form W-2s would be filed in cal-
endar year 2027. The Treasury Depart-
ment and the IRS estimate that 0.94 mil-
lion of these forms would have payments
affected by the change in the filing thresh-
old and would no longer need to be filed.
Multiplying the reduction in 0.94 million
forms filed by the 0.51 hours per form
time burden yields a decrease of 0.48 mil-
lion burden hours and then multiplying
by the $58.40 per hour monetization rate
provides an expected reduction in filing
burden of $28 million.
Also, prior to the passage of the
OBBBA, the IRS projected that 34.06
million Form W-2Gs would be filed in
calendar year 2027. The Treasury Depart-
ment and the IRS estimate that 19.06 mil-
lion of these forms would have payments
affected by the change in the filing thresh-
old and would no longer need to be filed.
Multiplying the reduction in 19.06 million
forms filed by the 0.4 hours per form time
burden yields a decrease of 7.62 million
burden hours and then multiplying by the
$58.40 per hour monetization rate pro-
vides an expected reduction in filing bur-
den of $445 million.
Finally, prior to the passage of the
OBBBA, the IRS projected that 47.8 thou-
sand Form 945s would be filed in calendar
year 2027. The Treasury Department and
the IRS estimate that 600 of these forms
would have payments affected by the
change in the filing threshold and would
no longer need to be filed. Multiplying
the reduction in 600 forms filed by the
8.18 hours per form time burden yields a
decrease of 5 thousand burden hours and
then multiplying by the $58.40 per hour
monetization rate provides an expected
reduction in filing burden of $292 thou-
sand.
The Treasury Department and the IRS
request comments on all aspects of these
estimates.

Bulletin No. 2026–19 905 May 4, 2026
Table 1. Estimate of the Reduction in Filing Burden from Increased Reporting Threshold, Calendar Year 2027
Form
Estimated Reduction in
Forms Filed Due to Increase
in Reporting Threshold
Burden Hours
Per Form
Total Reduction in
Burden Hours
Total Reduction in
Monetized Hours
1099-MISC9,320,0000.413,821,200$223,146,000
1099-NEC19,540,0000.254,885,000$285,284,000
W-2944,0000.51481,000$28,090,000
W-2G19,060,0000.407,624,000$445,242,000
9456008.185,000$292,000
Total48,864,600N/A16,816,000$982,054,000
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any Internal
Revenue law. Tax returns and tax return
information are confidential, unless sec-
tion 6103 authorizes disclosure.
III. Regulatory Flexibility Act
In accordance with the Regulatory
Flexibility Act (5 U.S.C. chapter 6)
(RFA), it is hereby certified that these
proposed regulations will not have a sig-
nificant economic impact on a substantial
number of small entities. Although the
proposed regulations may affect a sub-
stantial number of small entities, the eco-
nomic impact of the proposed regulations
is not likely to be significant. The Trea-
sury Department and the IRS estimate
that approximately 3.6 million taxpay-
ers are affected by the proposed regula-
tions, of which approximately 98 percent
are considered small entities with gross
receipts under $40 million. The economic
impact of these proposed regulations
is not likely to be significant, however,
because they do not impose any new
requirements on small entities but rather
increase the threshold at which they are
required to issue information returns,
thus reducing the amount of information
returns entities must issue. For example,
small entities with less than $40 million
in gross receipts will on average need to
issue 10 fewer information returns under
the increased threshold. The benefits
from the higher filing threshold and the
increased certainty from the proposed
regulations will be less than one percent
of gross revenues for these small entities.
Notwithstanding this certification, the
Treasury Department and the IRS wel-
come comments on the impact of these
proposed regulations on small entities.
IV. Submission to Small Business
Administration
Pursuant to section 7805(f) of the
Code, these proposed regulations will be
submitted to the Chief Counsel for the
Office of Advocacy of the Small Business
Administration for comment on its impact
on small business.
V. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates
Reform Act of 1995 (UMRA) requires
that agencies assess anticipated costs and
benefits and take certain other actions
before issuing a final rule that includes
any Federal mandate that may result in
expenditures in any one year by a State,
local, or Tribal government, in the aggre-
gate, or by the private sector, of $100 mil-
lion in 1995 dollars, updated annually for
inflation. This rule does 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 (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 gov-
ernments, and is not required by statute,
or preempts State law, unless the agency
meets the consultation and funding
requirements of section 6 of the Execu-
tive order. These proposed regulations do
not have federalism implications and do
not impose substantial direct compliance
costs on State and local governments or
preempt State law within the meaning of
the Executive order.
Comments and Requests for a Public
Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any comments that are
timely submitted to the Treasury Depart-
ment and the IRS as prescribed in this
preamble under the ADDRESSES head-
ing. The Treasury Department and the
IRS request comments on all aspects of
the proposed regulations. Any electronic
and paper comments submitted will be
available at https://www.regulations.gov
or upon request. Once submitted to the
Federal eRulemaking Portal, comments
cannot be edited or withdrawn.
A public hearing will be scheduled if
requested in writing by any person that
timely submits electronic or written com-
ments. If a public hearing is scheduled,
notice of the date, time, and place for the
public hearing will be published in the
Federal Register.
Drafting Information
The principal author of these proposed
regulations is the Office of the Associate
Chief Counsel (Procedure and Adminis-
tration). However, other personnel from
the Treasury Department and the IRS par-
ticipated in their development.

May 4, 2026 906 Bulletin No. 2026–19
List of Subjects
26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
26 CFR Part 31
Employment taxes, Income taxes,
Penalties, Pensions, Railroad retirement,
Reporting and recordkeeping require-
ments, Social security, Unemployment
compensation.
Proposed Amendments to the
Regulations
Accordingly, the Treasury Department
and IRS propose to amend 26 CFR parts 1
and 31 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 1.165-10 is revised to
read as follows:
§1.165-10 Wagering losses.
(a) In general. For purposes of losses
from wagering transactions, a deduction is
allowed under section 165(d) of the Internal
Revenue Code for 90 percent of the amount
of such losses during the taxable year, but
only to the extent of the gains from wager-
ing transactions during that year.
(b) Joint returns. In the case of spouses
making a joint return, 90 percent of the
combined losses of the spouses from
wagering transactions during the taxable
year are allowed as a deduction under sec-
tion 165(d) only to the extent of the com-
bined gains of the spouses from wagering
transactions during that year.
(c) Applicability date. This section
applies to taxable years beginning after
December 31, 2025.
Par. 3. Section 1.6041-1 is amended
by:
1. Revising the section heading, para-
graphs (a)(1)(i)(A) and (B), and paragraph
(a)(1)(iii).
2. In paragraph (a)(1)(v), designating
Example 1 and 2 as paragraphs (a)(1)(v)
(A) and (B).
3. Revising the first sentence of newly
designated paragraph (a)(1)(v)(A).
4. Revising newly designated para-
graph (a)(1)(v)(B).
5. Adding paragraph (a)(3).
6. Revising paragraph (j).
The revisions and addition read as fol-
lows:
§1.6041-1 Return of information as to
payments exceeding threshold.
(a) * * *
(1) * * *
(i) * * *
(A) Salaries, wages, commissions,
fees, and other forms of compensation for
services rendered that equal or exceed the
dollar threshold in effect for the calendar
year under section 6041(a) and (h).
(B) Interest (including original issue
discount), rents, royalties, annuities, pen-
sions, and other gains, profits, and income
that equal or exceed the dollar threshold in
effect for the calendar year under section
6041(a) and (h).
* * * * *
(iii) Information returns required
under section 6045(f) on or after January
1, 2007. For payments made on or after
January 1, 2007, to which section 6045(f)
(relating to payments to attorneys) applies,
the following rules apply. Notwithstand-
ing the provisions of paragraph (a)(1)(ii)
of this section, payments to an attorney
that are described in paragraph (a)(1)(i)
of this section but which otherwise would
be reportable under section 6045(f) are
reported under section 6041 and this sec-
tion and not section 6045(f) of the Code.
This exception applies only if the pay-
ments are reportable with respect to the
same payee under both sections 6041 and
6045(f). Thus, a person who, in the course
of a trade or business, pays taxable dam-
ages in an amount that equals or exceeds
the dollar threshold in effect for the cal-
endar year under section 6041(a) and (h)
to a claimant by paying that amount to
the claimant’s attorney is required to file
an information return under section 6041
with respect to the claimant, as well as
another information return under section
6045(f) with respect to the claimant’s
attorney. For provisions relating to infor-
mation reporting for payments to attor-
neys, see §1.6045–5.
* * * * *
(v) * * *
(A) * * * In 2026, Restaurant owner
A, in the course of business, pays $2,500
of fixed or determinable income to B, a
repairman, by credit card. * * *
(B) Example 2. In 2026, Restaurant
owner A, in the course of business, pays
$2,500 of fixed or determinable income
to B, a repairman, through a third party
payment network. B is one of a substantial
number of persons who have established
accounts with Y, a third party settlement
organization that provides standards and
mechanisms for settling the transactions
and guarantees payments to those persons
for goods or services purchased through
the network. Y is responsible for making
the payment to B. Under paragraph (a)
(1)(iv) of this section, A, as payor, is not
required to file an information return under
section 6041 with respect to the transaction
because the transaction is a third party net-
work transaction that is subject to reporting
under section 6050W. Solely for purposes
of determining whether A is required to
report under section 6041, the de minimis
threshold for third party network transac-
tions in §1.6050W–1(c)(4) is disregarded.
* * * * *
(3) Dollar threshold in effect for the
calendar year. For payments made before
January 1, 2026, the dollar threshold in
effect for the calendar year under section
6041(a) is $600. For payments made after
December 31, 2025, and before January
1, 2027, the dollar threshold in effect for
the calendar year under section 6041(a) is
$2,000. For payments made after Decem-
ber 31, 2026, the dollar threshold in
effect for the calendar year under section
6041(a) is $2,000 plus the inflation adjust-
ment provided in section 6041(h).
* * * * *
(j) Applicability date. This section
applies to payments made on or after Jan-
uary 1, 2026.
Par. 4. Section 1.6041-2 is amended
by:
1. Adding a heading to paragraph (a).
2. Revising the third and fourth sen-
tences of paragraph (a)(1).
3. Revising paragraphs (b)(1)(ii) and
(d).

Bulletin No. 2026–19 907 May 4, 2026
The addition and revisions read as fol-
lows:
§1.6041-2 Return of information as to
payments to employees.
(a) Reporting payments to employ-
ees--(1) * * * All other payments of
compensation, including the cash value
of payments made in any medium other
than cash, to an employee by the employ-
ee’s employer in the course of the trade
or business of the employer must also be
reported on Form W–2 if the total of such
payments and the amount of the employ-
ee’s wages (as defined in section 3401), if
any, required to be reported on Form W–2
equals or exceeds the dollar threshold in
effect for the calendar year under section
6041(a) and (h). For example, in 2026,
when the threshold in effect under section
6041(a) is $2,000, if a payment of $2,500
is made to an employee and $1,500 thereof
represents wages subject to withholding
under section 3402 and the remaining
$1,000 represents compensation not sub-
ject to withholding, such wages and com-
pensation must both be reported on Form
W–2. * * *
* * * * *
(b) * * *
(1) * * *
(ii) Described in section 72(m)(3)(B),
shall be reported on Forms 1096 and 1099
to the extent such amounts are includible
in the gross income of such beneficiary if
the amounts so includible equal or exceed
the dollar threshold in effect for the cal-
endar year under section 6041(a) and (h).
In addition, every trust described in sec-
tion 501(c)(17) which makes one or more
payments (including separation and sick
and accident benefits) in an amount that
equals or exceeds the dollar threshold in
effect for the calendar year under section
6041(a) and (h) to an individual must file
an annual information return on Form
1096, accompanied by a statement on
Form 1099, for each such individual. Pay-
ments made by an employer or a person
other than the trustee of the trust should
not be considered in determining whether
the amount paid by the trustee equals or
exceeds the dollar threshold in effect for
the calendar year under section 6041(a)
and (h).
* * * * *
(d) Applicability date. This section
applies to returns filed with respect to pay-
ments made on or after January 1, 2026.
Par. 5. Section 1.6041-7 is amended
by revising paragraph (b)(1) to read as
follows:
§1.6041-7 Magnetic media
requirement.
* * * * *
(b) * * *
(1) For calendar years beginning on or
after January 1, 1971, a health care car-
rier, or an agent thereof, making payment
of fees or other compensation to provid-
ers of medical and health care services,
may make a separate return on magnetic
media for each separate department
within a specific line of such carrier’s
business, so long as all of such returns
taken together contain all of the infor-
mation required by section 6041 with
respect to each provider of medical and
health care services to whom such health
care carrier makes payments that equal or
exceed the dollar threshold in effect for
the calendar year under section 6041(a)
and (h).
* * * * *
Par. 6. Section 1.6041-10 is amended
by:
1. Revising paragraph (b)(1)(i).
2. Revising the introductory text of
paragraph (g)(5).
3. In paragraph (g)(5), designating
Examples 1 through 6 as paragraphs (g)
(5)(i) through (vi).
4. Revising newly designated para-
graphs (g)(5)(i) and (ii).
5. In newly designated paragraph (g)
(5)(iv), removing the language “example
3” and adding, in its place, the language
“in paragraph (g)(5)(iii) of this section
(Example 3)”.
6. Revising newly designated para-
graph (g)(5)(v).
7. Revising paragraph (i).
The revisions read as follows:
§1.6041-10 Return of information as
to payments of winnings from bingo,
keno, and slot machine play.
* * * * *
(b) * * *
(1) * * *
(i) For purposes of this section, the
term reportable gambling winnings is
defined as follows:
(A) For bingo, the term reportable
gambling winnings means winnings
that equal or exceed the dollar thresh-
old in effect for the calendar year under
section 6041(a) and (h) from one bingo
game, without reduction for the amount
wagered. All winnings received from all
wagers made during one bingo game are
combined (for example, all winnings from
all cards played during one bingo game
are combined).
(B) For keno, the term reportable gam-
bling winnings means winnings that equal
or exceed the dollar threshold in effect for
the calendar year under section 6041(a)
and (h) from one keno game reduced by
the amount wagered on the same keno
game. All winnings received from all
wagers made during one keno game are
combined (for example, all winnings from
all “ways” on a multi-way keno ticket are
combined).
(C) For slot machine play, the term
reportable gambling winnings means
winnings that equal or exceed the dollar
threshold in effect for the calendar year
under section 6041(a) and (h) from one
slot machine play, without reduction for
the amount wagered.
* * * * *
(g) * * *
(5) Examples. The following examples
illustrate the provisions of this section.
For each example, assume that for pur-
poses of the aggregate reporting method
in this paragraph (g), casino R’s “infor-
mation reporting period” for all calendar
years is a gaming day that begins at 3 a.m.
and ends at 2:59 a.m. the following day
(except for January 1 and December 31),
that (ignoring the inflation adjustment in
6041(h) for simplicity of illustration) the
dollar threshold in effect for each calen-
dar year under section 6041(a) is $2,000,
and that individuals C, D, and E are U.S.
persons.
(i) Example 1. On Day 1, between 7 a.m. and 4
p.m., C places five wagers at casino R on five differ-
ent slot machines. The first two wagers result in no
win. The third wager results in a $2,000 win. The
fourth wager results in a $2,500 win. The fifth wager
results in an $800 win:
(A) Under paragraph (b)(1)(i)(C) of this section,
there are reportable gambling winnings from the slot
machine play of $4,500 ($2,000 + $2,500). The $800
win is not a reportable gambling winning from slot

May 4, 2026 908 Bulletin No. 2026–19
machine play because it does not equal or exceed the
dollar threshold.
(B) Because all the amounts were won on the
same type of game (even though each of the win-
nings occurred on different machines) during the
same information reporting period, R is permitted
to use the aggregate reporting method under this
paragraph (g). If R decides not to use the aggregate
reporting method, a separate Form W–2G would
have to be filed and furnished for the payment of
reportable gambling winnings of $2,000 and for the
payment of reportable gambling winnings of $2,500.
However, if R decides to use the aggregate reporting
method, R may report total reportable gambling win-
nings from slot machine play of $4,500 ($2,000 +
$2,500) on one Form W–2G.
(ii) Example 2. Assume the same facts as in
paragraph (g)(5)(i) of this section (Example 1),
except that in addition to the winnings described
in paragraph (g)(5)(i) of this section (Example 1),
at 5 a.m. on Day 2, C wins $3,250 from one slot
machine play at casino R. Even though C played
the same type of game (slot machine play) on Day
1 and Day 2, under paragraph (b)(2) of this section,
the win at 5 a.m. on Day 2 is a win during a separate
information reporting period. Under paragraph (g)
(2)(i) of this section, the $3,250 of reportable gam-
bling winnings on Day 2 cannot be aggregated with
the reportable gambling winnings of $4,500 from
Day 1 on a single Form W–2G. Accordingly, if R
uses the aggregate reporting method, R must file
two Forms W–2G with respect to C’s reportable
gambling winnings on Day 1 and Day 2. R must
report $4,500 of reportable gambling winnings
from slot machine play paid to C on Day 1 on the
first Form W–2G, and $3,250 of reportable gam-
bling winnings from slot machine play paid to C on
Day 2 on the second Form W–2G.
* * * * *
(v) Example 5. At 2 p.m. on Day 1, D won
$2,000 (after reducing the amount of the win by
the amount wagered) playing one keno game at
casino R. D provides R with his driver’s license.
The driver’s license has D’s photograph on it, as
well as D’s name and address. The driver’s license
does not include D’s social security number. D can-
not remember his social security number and has
no other identification at the time with his social
security number on it. D does not provide R with
his social security number before R pays the win-
nings to D. Because D cannot remember his social
security number, D cannot complete and sign a
Form W–9. R deducts and withholds under the
backup withholding provisions of section 3406(a)
and pays the remainder to D. D returns to casino R
and at 6 p.m. on Day 1 wins $2,500 (after reduc-
ing the amount of the win by the amount wagered)
in one keno game. D provides R with his driver’s
license as well as D’s social security card. R gen-
erally uses the aggregate reporting method and,
in all cases where it is used, R complies with the
requirements of this paragraph (g). At 8 p.m. and
10 p.m. on Day 1, D wins an additional $2,800 and
$2,700 (after reducing the amount of the win by
the amount wagered), respectively, from two dif-
ferent keno games. For each of these two wins,
an employee of R obtains the information from D
required by this paragraph (g). Under paragraph
(b)(1)(i)(B) of this section, each of D’s wins from
the four games of keno on Day 1 ($2,000, $2,500,
$2,800, and $2,700) are reportable gambling win-
nings. Because D’s first win on Day 1 was at 2 p.m.
and D’s last win on Day 1 was at 10 p.m., all of
D’s reportable gambling winnings from keno are
won during the same information reporting period.
Because R satisfies the requirements of paragraph
(g)(2)(i) of this section, R may use the aggregate
reporting method to report D’s reportable gambling
winnings from keno. However, pursuant to para-
graph (g)(4)(iii) of this section, the $2,000 payment
made to D at 2 p.m. cannot be reported under the
aggregate reporting method because that payment
was subject to backup withholding. Accordingly, if
R uses the aggregate reporting method under this
paragraph (g), R will have to file two Forms W–2G
with respect to D’s reportable gambling winnings
from keno on Day 1. On the first Form W–2G, R
will report $2,000 of reportable gambling win-
nings and of the amount of backup withholding
with respect to the 2 p.m. win from keno, and, on
the second Form W–2G, R will report $8,000 of
reportable gambling winnings from keno (repre-
senting the three payments of $2,500, $2,800, and
$2,700 that D won between 6 p.m. and 10 p.m. on
Day 1).
* * * * *
(i) Applicability date. This section
applies to payments of reportable gam-
bling winnings from bingo, keno, or slot
machine play made on or after January 1,
2026.
* * * * *
Par. 7. Section 1.6041A-1 is amended
by revising paragraphs (d)(4)(ii) and (iii)
to read as follows:
§1.6041A-1 Returns regarding
payments of remuneration for services
and certain direct sales.
* * * * *
(d) * * *
(4) * * *
(ii) Examples. The provisions of this
paragraph (d)(4) are illustrated by the fol-
lowing examples:
(A) Example 1. In 2026, service recipient A, in
the course of its business, pays by credit card remu-
neration of $2,500 to service provider B for services
performed by B. B is one of a network of unrelated
persons that has agreed to accept A’s credit card as
payment under an agreement that provides stan-
dards and mechanisms for settling the transactions
between a merchant acquiring bank and the persons
who accept the cards. Merchant acquiring bank Y
is responsible for making the payment to B. Under
paragraph (d)(4)(i) of this section, A is not required
to file an information return under section 6041A(a)
with respect to the transaction because Y, as the pay-
ment settlement entity for the payment card transac-
tion, is required to file an information return under
section 6050W.
(B) Example 2. In 2026, service recipient A, in
the course of business, pays through a third party
payment network $2,500 to B, a repairman, through
a third party payment network. B is one of a sub-
stantial number of persons who have established
accounts with Y, a third party settlement organization
that provides standards and mechanisms for settling
the transactions and guarantees payments to those
persons for goods or services purchased through the
network. Y is responsible for making the payment to
B. Under paragraph (d)(4)(i) of this section, A is not
required to file an information return under section
6041A(a) with respect to the transaction because the
transaction is a third party network transaction that
is subject to reporting under section 6050W. Solely
for purposes of determining whether the transaction
is subject to reporting under section 6041A, the de
minimis threshold for third party network transac-
tions in §1.6050W-1(c)(4) is disregarded.
(iii) Applicability date. This section
applies to payments made by payment
card or through a third party payment net-
work on or after January 1, 2026.
* * * * *
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME
TAX AT SOURCE
Par. 8. The authority citation for part
31 continues to read in part as follows:
Authority: 26 U.S.C. 7805.
* * * * *
Par. 9. Section 31.3406-0 is amended
by revising the entry for §31.3406(b)(3)-
1(b)(3) to read as follows:
§31.3406-0 Outline of the backup
withholding regulations.
* * * * *
§31.3406(b)(3)-1 Reportable payments
of rents, commissions, nonemployee
compensation, etc.
* * * * *
(b) * * *
(3) Payments exceeding threshold.
* * * * *
Par. 10. Section 31.3406(b)(3)-1 is
amended by:
1. Revising the second sentence of
paragraph (a).
2. Revising the heading of paragraph
(b)(3) and revising paragraph (b)(3)(i).
3. Revising paragraph (b)(3)(ii)(A).
4. Revising the heading and the first
sentence of paragraph (b)(3)(ii)(B).
The revisions read as follows:

Bulletin No. 2026–19 909 May 4, 2026
§31.3406(b)(3)-1 Reportable payments
of rents, commissions, nonemployee
compensation, etc.
(a) * * * See paragraph (b) of this sec-
tion for an exception concerning payments
aggregating less than the dollar threshold
in effect for the calendar year under sec-
tion 6041(a) and (h). * * *
(b) * * *
(3) Payments exceeding threshold—(i)
In general. A payment is a reportable pay-
ment under paragraph (a) of this section
only if the aggregate amount of the current
payment and all previous payments to the
payee during the calendar year equals or
exceeds the dollar threshold in effect for the
calendar year under section 6041(a) and (h).
The amount subject to withholding is the
entire amount of the payment that causes
the total amount paid to the payee to equal
or exceed the dollar threshold in effect for
the calendar year under section 6041(a) and
(h), plus the amount of any subsequent pay-
ments made to the payee during that calen-
dar year. This paragraph (b)(3)(i) does not
apply to gambling winnings (as provided in
§31.3406(g)–2(d)(1)).
(ii) * * *
(A) The aggregation rule. The aggre-
gation rule of paragraph (b)(3)(i) of this
section does not apply if the payor was
required to make an information return
under section 6041 or 6041A(a) for the
preceding calendar year with respect to
payments to the payee, or the payor was
required to withhold under section 3406
during the preceding calendar year with
respect to payments to the payee that were
reportable under section 6041 or 6041A(a).
(B) Determination of whether pay-
ments exceed the dollar threshold. In
determining whether payments to a payee
equal or exceed the dollar threshold in
effect for the calendar year under section
6041(a) and (h) for purposes of withhold-
ing under section 3406, the payor must
aggregate only payments of the same kind
made to the same payee. * * *
* * * * *
Par. 11. Section 31.3406(g)-2 is
amended by:
1. Revising the second sentence of
paragraph (d)(2).
2. Revising paragraph (h).
The revisions read as follows:
§31.3406(g)-2 Exception for reportable
payment for which withholding is
otherwise required.
* * * * *
(d) * * *
(2) * * * A gambling winning (other
than a winning from bingo, keno, or slot
machines) is a reportable gambling win-
ning only if the amount paid with respect
to the wager equals or exceeds the dol-
lar amount in effect for the calendar year
under section 6041(a) and (h) and if the
proceeds are at least 300 times as large as
the amount wagered. * * *
* * * * *
(h) Applicability date. This section
applies to payments of reportable gam-
bling winnings paid with respect to a win-
ning event that occurs on or after January
1, 2026.
Frank J. Bisignano,
Chief Executive Officer.
(Filed by the Office of the Federal Register April 16,
2026, 8:45 a.m., and published in the issue of the
Federal Register for April 17, 2026, 91 FR 20599)

Bulletin No. 2026–19 i May 4, 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.

May 4, 2026 ii Bulletin No. 2026–19
Numerical Finding List
1
Bulletin 2026–19
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
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
Proposed Regulations:
REG-101952-24, 2026-03 I.R.B. 345
REG-110519-25, 2026-03 I.R.B. 353
REG-132251-11; REG-134219-08,
2026-03 I.R.B. 358
REG-103430-24, 2026-05 I.R.B. 447
REG-112829-25, 2026-05 I.R.B. 452
REG-113515-25, 2026-05 I.R.B. 455
REG-121244-23, 2026-09 I.R.B. 579
REG-105064-25, 2026-13 I.R.B. 735
REG-108921-25, 2026-13 I.R.B. 756
REG-117002-25, 2026-13 I.R.B. 761
REG-117270-25, 2026-13 I.R.B. 772
REG-117298-21, 2026-14 I.R.B. 784
REG-114499-25, 2026-18 I.R.B. 883
REG-113229-25, 2026-19 I.R.B. 900
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
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
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
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. 2026–19 iii May 4, 2026
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2026–19
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.

Internal Revenue Service
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