Internal Revenue Bulletin 2026-23 (PDF rendition): IRS Announcements

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Bulletin No. 2026–23
June 1, 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, INCOME TAX
T.D. 10048, page 1558.
The final regulations modify information reporting obligations
with respect to sales or exchanges of certain interests in
partnerships owning inventory or unrealized receivables.
Specifically, the final regulations eliminate a regulatory
requirement that partnerships furnish partners that bought
or sold interests in the partnership certain computational
information by January 31 of the year following the calendar
year in which the sale or exchange occurred. As a result, the
final regulations result in partnerships having additional time
(generally, until the due date of the partnership’s return) to
compute and furnish such information.
EMPLOYEE PLANS
Notice 2026-31, page 1562.
This notice sets forth updates on the corporate bond
monthly yield curve, the corresponding spot segment
rates for April 2026 used under § 417(e)(3)(D), the
24-month average segment rates applicable for May
2026, and the 30-year Treasury rates, as reflected by
the application of § 430(h)(2)(C)(iv).
Notice 2026-34, page 1565.
This notice sets forth the 2026 Cumulative List of
Changes in Plan Qualification Requirements for Defined
Benefit Qualified Pre-approved Plans (2026 Cumulative
List). The 2026 Cumulative List will assist providers
applying to the Internal Revenue Service (IRS) for opin-
ion letters for the fourth remedial amendment cycle
for defined benefit qualified pre-approved plans (Cycle
4) under the IRS’s pre-approved plan program. Cycle 4
began on April 1, 2025. The Cycle 4 submission period
begins on August 1, 2026, and ends on July 31, 2027.
The 2026 Cumulative List identifies recent changes in the
qualification requirements of the Internal Revenue Code
that were not taken into account during the first three
remedial amendment cycles for defined benefit qualified
pre-approved plans and that will be taken into account by
the IRS with respect to the form of a plan submitted to
the IRS for Cycle 4.
EXEMPT ORGANIZATIONS
Announcement 2026-10, page 1569.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
SPECIAL ANNOUNCEMENT
AOD 2026-1, page 1556.
This Action on Decision announces the IRS’s acquiescence
in result only to the April 2, 2024 Tax Court decision
Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner,
162 T.C. 148. In that case, the Tax Court held that the
then-applicable version of IRC 7508A(d) provided for an
automatic and mandatory 60-day postponement of certain
tax-related deadlines for all taxpayers in Ohio affected by
the federally declared disaster for the COVID-19 pandemic,
beginning January 20, 2020, and ending on March 20,
2020. In so holding, the Tax Court invalidated Treas. Reg.
301.7508A(g)(1) and (2), which limit the non-pension-re-
lated time-sensitive acts that are postponed for the manda-
tory 60-day postponement period to acts determined to be
postponed by the Secretary’s exercise of authority under
section 7508A(a).
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 1, 2026 Bulletin No. 2026–23

ACTION ON DECISION
Subject: Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court).
Issue: Whether the originally enacted version of 26 U.S.C. § 7508A(d)
1
provided for an automatic and mandatory 60-day post-
ponement of certain tax-related deadlines for all taxpayers affected by the federally declared disaster for the COVID-19 pandemic,
beginning January 20, 2020.
Discussion: Under section 7508A(a), the Secretary is authorized to postpone certain deadlines for up to one year for taxpayers
determined to be affected by a federally declared disaster. The Secretary has discretion to determine (1) who is an affected taxpayer;
(2) which deadlines should be postponed; and (3) how long the postponement should last (though no longer than one year). A feder-
ally declared disaster includes both a major disaster declared under section 401 of the Stafford Act ( 42 U.S.C. § 5121, et seq.) and
an emergency declared under section 501 of the Stafford Act, but there is no distinction between these types of events for section
7508A(a) purposes. Treas. Reg. § 1.165-11(b)(1). The Federal Emergency Management Agency (FEMA) determines when a federally
declared disaster exists and whether Public Assistance and/or Individual Assistance will be given, then issues the disaster declaration,
signed by the President. Once the disaster declaration is issued, the Secretary is authorized to exercise discretion to postpone tax-re-
lated deadlines for affected taxpayers. The Secretary may postpone deadlines for the acts listed in section 7508(a)(1), including filing
returns, paying taxes, filing petitions with the U.S. Tax Court, certain government acts, and any other act required or permitted under
the Internal Revenue Code specified by the Secretary.
2
When an affected taxpayer is required to perform a tax-related act by a due
date that falls within the postponement period, the affected taxpayer is eligible for postponement of the time to perform the act until
the last day of the period determined by the Secretary. Treas. Reg. § 301.7508A-1(b)(2). The Secretary may also disregard the disaster
postponement period when calculating the amount of any interest, penalty, additional amount, or addition to the tax owed related to
due dates that fall within the postponement period, or when calculating the amount of any credit or refund. I.R.C. § 7508A(a)(2)-(3).
In 2019, Congress added paragraph (d) to section 7508A.
3
Paragraph (d) gave taxpayers a mandatory minimum 60-day postponement
of certain tax-related deadlines, effective for disasters declared after December 20, 2019. The text of paragraph (d) specified that
mandatory relief was to be applied “in the same manner as” discretionary relief under section 7508A(a), but it did not identify which
deadlines (i.e., taxpayer acts, government acts, or both) should be postponed. Paragraph (d) also failed to explain how to calculate the
mandatory 60-day period if there is no incident date of the disaster specified in the declaration, whether mandatory relief can run lon-
ger than the year-long limit for discretionary relief under section 7508A(a), and whether mandatory relief applies to every federally
declared disaster. It is this version of the statute that was in effect at the time of the issuance of the COVID-19 disaster declarations
discussed below.
To address these ambiguities in the statutory language, the Treasury Department published final regulations in June 2021, effective
for disasters declared after December 20, 2019. Treas. Reg. §§ 301.7508A-1(g) and (h) specify that to apply section 7508A(d) “in
the same manner” as section 7508A(a), the Secretary must first exercise discretion before the mandatory 60-day postponement takes
effect. The deadlines postponed under the mandatory 60-day postponement are the same deadlines determined by the Secretary in
the grant of discretionary relief under section 7508A(a). The mandatory relief postponement period runs concurrently with the dis-
cretionary relief period determined by the Secretary, which cannot last longer than one year. Finally, mandatory relief under section
7508A(d) does not apply when the disaster declaration fails to specify an incident date of the disaster.
In November 2021, Congress amended paragraph (d), effective for disasters declared after November 15, 2021, replacing the “in the
same manner as” language, which tied the application of mandatory relief to discretionary relief, with a statement that the period of
mandatory relief “shall be disregarded” in determining the timeliness of the specified acts. See Infrastructure Investment and Jobs
Act, Pub. L. No. 117-58, § 80501, 135 Stat. 429, 1335 (2021). The amended version of section 7508A(d) also clarified that only tax-
payer acts (not government acts) are to be mandatorily postponed. It also explained how to calculate the 60-day postponement period
if there is no incident date of the disaster stated in the disaster declaration and specified that mandatory relief applies only to major
disasters in response to which Individual Assistance is provided by FEMA (i.e., not to every federally declared disaster).
On March 13, 2020, the President issued a nationwide emergency declaration without an incident date in response to the COVID-19
pandemic. Pursuant to the emergency declaration, the Secretary then issued a series of notices granting discretionary relief under
section 7508A(a) and citing the President’s nationwide emergency declaration. See, e.g., Notice 2020-23, 2020-18 I.R.B. 742, which
1
All statutory references hereafter are made to 26 U.S.C. (I.R.C.) unless otherwise specified.
2
See also Treas. Reg. § 301.7508A-1(c).
3
See Further Consolidated Appropriations Act, 2020, Pub. L. No. 116-94, div. Q, § 205, 133 Stat. 2534, 3245–46 (2019).
June 1, 2026 1556 Bulletin No. 2026–23

postponed, among other things, the filing deadline for most federal income tax returns from April 15, 2020, until July 15, 2020. On
March 31, 2020, the President issued a major disaster declaration for COVID-19 for Ohio, identifying the disaster as “beginning
on January 20, 2020, and continuing.”
4
The IRS did not provide any discretionary or mandatory relief based on this or any other
state-specific major disaster declaration.
In Abdo v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court), the IRS issued a notice of deficiency to petitioners
at their last known address in Ohio on December 2, 2019. Their deadline to file a petition with the Tax Court was March 2, 2020, but
petitioners didn’t mail their petition to the court until March 17, 2020. The Commissioner moved to dismiss the Abdo petition for
untimeliness, but petitioners argued that the Ohio major disaster declaration entitled them to a mandatory 60-day postponement of
time to file a petition from January 20, 2020, to March 20, 2020, rendering timely the petition they filed on March 17, 2020.
The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that
section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incor-
porated all of the acts referenced by section 7508A(a), from the earliest incident date specified in the Ohio declaration, and lasting
for at least 60 days until March 20, 2020. Based upon this reasoning, the Tax Court determined petitioners’ petition was timely filed.
In so holding, the Tax Court invalidated Treas. Reg. §§ 301.7508A(g)(1) and (2), which limited non-pension-related time-sensitive
acts postponed for the mandatory 60-day period only to acts determined to be postponed by the Secretary’s exercise of discretionary
authority under section 7508A(a).
5
The Tax Court did not express a view on what the outer limits of the mandatory postponement
period could be when a disaster declaration omits an ending date or is extended. Abdo, 162 T.C. at 169 n.13. The IRS disagrees with
the Tax Court’s holding that the phrase “in the same manner” in former section 7508A(d) is unambiguous and will continue to defend
its interpretation of that provision in the Treasury Regulations, which required the Secretary to first specify whether, and for what
acts, discretionary relief would be granted before section 7508A(d)’s mandatory minimum postponement period of 60 days would
be triggered.
Recommendation: Acquiescence only to the Tax Court’s holding that the COVID-19 disaster declarations created a mandatory
60-day postponement period from January 20, 2020, to March 20, 2020. The IRS does not acquiesce to the reasoning of the opinion,
the invalidation of the relevant portions of the regulation, or an interpretation that would result in any further postponement beyond
the 60 days provided by the Tax Court in Abdo.
________________________________
Scott Panitz
Attorney, Branch 6
(Procedure & Administration)
Reviewer:
ACK
MEA
Approved: KENNETH KIES
Chief Counsel (acting)
Internal Revenue Service
By: ________________________________
Paul T. Butler
Associate Chief Counsel
Procedure & Administration
4
Identical major disaster declarations were issued for all U.S. states and territories.
5
The IRS disagrees with the partial invalidation of the regulations, but notes that Treas. Reg. §§ 301.7508A(g)(1) and (2) were rendered obsolete following the enactment of the November
2021 amendments to section 7508A(d).
Bulletin No. 2026–23 1557 June 1, 2026

June 1, 2026 1558 Bulletin No. 2026–23
Part I
26 CFR 1.6050K-1: Returns relating to sales or
exchanges of certain partnership interests.
T.D. 10048
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Returns Relating to Sales
or Exchanges of Certain
Partnership Interests
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations modifying information
reporting obligations with respect to sales
or exchanges of certain interests in part-
nerships owning inventory or unrealized
receivables.
DATES: Effective date: These regula-
tions are effective on May 20, 2026.
Applicability date: For dates of appli-
cability, see §1.6050K-1(h).
FOR FURTHER INFORMATION
CONTACT: Benjamin Weaver, (202)
317-6850 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Authority
This document contains final regula-
tions amending the Income Tax Regula-
tions (26 CFR part 1) under section 6050K
of the Internal Revenue Code (Code) by
removing §1.6050K-1(c)(2).
Section 6050K(a) provides that, except
as provided in regulations prescribed by
the Secretary of the Treasury or the Sec-
retary’s delegate (Secretary), a partner-
ship is required to file a return if there is
an exchange described in section 751(a)
of the Code of any interest in the part-
nership during any calendar year. Section
6050K(a) also contains express delega-
tions of authority for the Secretary to pro-
mulgate regulations prescribing the infor-
mation required to be disclosed on such
partnership returns, the manner in which
such returns are made, and the due date of
such returns.
Section 6031(a) of the Code provides
an express grant of authority for the Sec-
retary to prescribe in forms or regulations
partnership reporting information required
“for the purpose of carrying out the provi-
sions of subtitle A.”
Section 7805(a) of the Code authorizes
the Secretary to “prescribe all needful
rules and regulations for the enforcement
of [the Code], including all rules and reg-
ulations as may be necessary by reason of
any alteration of law in relation to internal
revenue.”
Background
I. Statutory and Regulatory Background
Section 741 of the Code provides that
gain or loss recognized by a transferor
partner upon sale or exchange of a part-
nership interest is considered as gain or
loss from the sale or exchange of a cap-
ital asset, except as provided in section
751. Section 751(a) provides that the
amount of any money, or the fair mar-
ket value of any property, received by a
transferor partner in exchange for all or a
part of the transferor partner’s interest in
the partnership attributable to (1) unreal-
ized receivables of the partnership, or (2)
inventory items of the partnership, will
be considered as an amount realized from
the sale or exchange of property other
than a capital asset. Section 1.6050K-
1(a)(4)(i) refers to a sale or exchange to
which section 751(a) applies as a “sec-
tion 751(a) exchange.”
Section 6050K(a) requires a partner-
ship to file a return if there is a section
751(a) exchange of any interest in the
partnership during any calendar year. Sec-
tion 6050K(a) further provides that the
return must state the name and address of
the transferee and transferor in the section
751(a) exchange and such other informa-
tion as the Secretary may by regulations
prescribe.
Section 1.6050K-1(a)(1) generally
requires a partnership to make a separate
return using Form 8308, Report of a Sale
or Exchange of Certain Partnership Inter-
ests, with respect to each section 751(a)
exchange. Section 1.6050K-1(b) requires
the Form 8308 to include the following
information: (1) the names, addresses,
and taxpayer identification numbers of the
transferee and transferor in the exchange
and of the partnership filing the return;
(2) the date of the exchange; and (3) such
other information as may be required
by Form 8308 or its instructions. Sec-
tion 1.6050K-1(f)(1) requires a partner-
ship to file Form 8308 as an attachment to
its Form 1065, U.S. Return of Partnership
Income, for the partnership’s taxable year
that includes the last day of the calendar
year in which the section 751(a) exchange
took place.
Section 6050K(b) requires a partner-
ship to provide certain information to
transferors and transferees that are parties
to a section 751(a) exchange on or before
January 31 of the year following the cal-
endar year of the section 751(a) exchange.
Among other things, the information pro-
vided to each transferor and transferee
must include the information required
to be shown on the partnership’s return
under section 6050K(a) with respect to
such person.
Section 6050K(c)(1) provides that the
transferor of the partnership interest must
notify the partnership of any exchange
described in section 6050K(a). Under
section 6050K(c)(2), a partnership is
not required to make a return under sec-
tion 6050K with respect to any exchange
until the partnership is notified of such
exchange.
Section 1.6050K-1(c)(1) clarifies that
each partnership that is required to file a
Form 8308 must furnish a statement to
the transferor and transferee by the later
of (1) January 31 of the year following
the calendar year in which the section
751(a) exchange occurs, or (2) 30 days
after the partnership receives notice of
the exchange as specified under section
6050K(c) and §1.6050K-1(e). Prior to its
modification by these final regulations,
§1.6050K-1(c)(1) generally required a
partnership to use a copy of the com-

Bulletin No. 2026–23 1559 June 1, 2026
pleted Form 8308 as the required state-
ment.
In addition, prior to its removal by
these final regulations, §1.6050K-1(c)(2)
required a partnership to furnish to a trans-
feror partner the information necessary for
the transferor to make the transferor part-
ner’s required statement in §1.751-1(a)
(3). Section 1.751-1(a)(3) requires a trans-
feror partner in a section 751(a) exchange
to submit with the transferor partner’s
income tax return for the taxable year in
which the sale or exchange occurs a state-
ment separately stating the date of the sale
or exchange, the amount of any gain or
loss attributable to section 751 property,
and the amount of any gain or loss attrib-
utable to capital gain or loss on the sale
of the partnership interest. Consistent with
§1.6050K-1(c)(2), Part IV of Form 8308
requires a partnership to report, among
other items, the partnership’s gain or loss
from a deemed sale under section 751
and the transferor partner’s share of such
amount.
The Department of the Treasury (Trea-
sury Department) and the IRS received
comments from stakeholders that many
partnerships are unable to furnish the
information required in Part IV of the
Form 8308 to transferors and transferees
by the January 31 due date prescribed by
§1.6050K-1(c)(1) because, in many cases,
partnerships do not have all the informa-
tion required by Part IV of the Form 8308
by January 31 of the year following the
calendar year in which the section 751(a)
exchange occurred.
II. Proposed Regulations
In response to those comments, on
August 19, 2025, the Treasury Depart-
ment and the IRS published a notice of
proposed rulemaking (REG-108822-25)
in the Federal Register (90 FR 40269)
to propose the removal of §1.6050K-
1(c)(2) (proposed regulations). The pro-
posed regulations also proposed to mod-
ify §1.6050K-1(c)(1) by removing the
reference to a “completed copy of Form
8308” and replacing it with a reference to
“a copy of Form 8308 filled out in accor-
dance with the instructions to the form.”
In addition, the preamble to the proposed
regulations explained that the Treasury
Department and the IRS would update
the instructions for Form 8308 to provide
that only the information in Parts I, II, and
III is required by the due dates of section
6050K. The instructions to Form 8308
were updated on November 5, 2025.
As a result of the proposed changes to
§1.6050K-1 and the associated changes in
the instructions to Form 8308, a partner-
ship would be required to furnish the infor-
mation reported on only Parts I, II, and III
of Form 8308, or a statement that includes
the same information, to the transferor and
transferee in a section 751(a) exchange
by the later of (1) January 31 of the year
following the calendar year in which the
section 751(a) exchange occurred, or (2)
30 days after the partnership has received
notice of the exchange as specified under
section 6050K and §1.6050K-1.
Further, the preamble to the proposed
regulations explained that the Treasury
Department and the IRS would update
the Instructions for Form 8308 to make
clear that a partnership must file a com-
pleted Form 8308, including Part IV,
as an attachment to its Form 1065. The
update to the Form 8308 instructions
reflects this. Accordingly, and pursuant to
§1.6031(a)-1(a)(2), which provides that a
partnership return must contain the infor-
mation required by the prescribed form
and the accompanying instructions, a part-
nership would be required to file the com-
pleted Form 8308, including Part IV, as an
attachment to its Form 1065, for the tax-
able year of the partnership that includes
the last day of the calendar year in which
the section 751(a) exchange took place.
Thus, the requirement that a partnership
file a completed Form 8308, including
Part IV, as an attachment to its Form 1065
would remain unchanged by the proposed
regulations.
The preamble to the proposed regula-
tions further explained that, pursuant to
§1.6031(b)-1T(a)(3), the partnership will
also continue to be required to report the
information required of the transferor in
§1.751-1(a)(3) to the transferor (including
the information required in Part IV of the
Form 8308), in the Schedule K-1 (Form
1065), Partner’s Share of Income, Deduc-
tions, Credits, etc., issued to the transferor
partner as provided by the Form and Instruc-
tions to the Schedule K-1 (Form 1065).
Finally, the proposed regulations would
modify §1.6050K-1(c)(1)(i) to clarify that
the partnership will be providing to the
IRS the information included on a substi-
tute statement furnished in lieu of a Form
8308 under §1.6050K-1(c)(1).
The preamble to the proposed regu-
lations stated that §1.6050K-1(c)(2) was
proposed to be removed on the date the
regulations are published as final regula-
tions in the Federal Register. The amend-
ment to §1.6050K-1(c)(1)(i) was proposed
to apply to returns filed for taxable years
ending on or after the date the regulations
are published as final regulations in the
Federal Register. The preamble to the
proposed regulations stated that a partner-
ship may rely on the proposed regulations,
and the description of the anticipated
changes to the instructions to Form 8308
contained in the preamble to the proposed
regulations, with respect to section 751(a)
exchanges occurring on or after January 1,
2025, and before the date the regulations
are published as final regulations in the
Federal Register.
Summary of Comments and
Explanation of Revisions
The Treasury Department and IRS did
not receive any comments pertaining to
the proposed regulations, and no public
hearing was requested or held. Accord-
ingly, these final regulations adopt the
proposed regulations without change.
Special Analyses
I. Regulatory Planning and Review
These final regulations are not subject
to review under section 6(b) of Executive
Order 12866 pursuant to the Memoran-
dum of Agreement (July 4, 2025) between
the Treasury Department and the Office of
Management and Budget (OMB) regard-
ing review of tax regulations. Therefore,
a regulatory impact assessment is not
required.
The Executive Order 14192 designa-
tion for this rule is expected to be dereg-
ulatory.
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

June 1, 2026 1560 Bulletin No. 2026–23
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.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
control number. These final regulations do
not impose a new collection of informa-
tion or modify an existing collection of
information.
III. Regulatory Flexibility Act
It is hereby certified that the final reg-
ulations will not have a significant eco-
nomic impact on a substantial number of
small entities pursuant to the Regulatory
Flexibility Act (5 U.S.C. chapter 6). These
final regulations affect partnerships for
which there is a section 751(a) exchange
(as defined in §1.6050K-1(a)(4)(i)). These
final regulations will likely affect a sub-
stantial number of small entities organized
as partnerships for Federal tax purposes,
but the impact of the final regulations is
limited because the final regulations delay
the date by which partnerships must pro-
vide transferors of interests in the part-
nership the information necessary for
the transferor to make the transferor’s
required statement under §1.751-1(a)(3).
This delay benefits the partnerships by
providing additional time to furnish the
information but will not have a significant
economic impact. Accordingly, a regula-
tory flexibility analysis under the Regula-
tory Flexibility Act is not required.
IV. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandate
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
million (updated annually for inflation).
These final 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.
V. 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 Executive
order. These final 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 Exec-
utive order.
VI. Small Business Administration
Pursuant to section 7805(f) of the Code,
the proposed rule preceding these final
regulations was submitted to the Chief
Counsel for Advocacy of the Small Busi-
ness Administration for comment on its
impact on small business. No comments
were received from the Chief Counsel for
Advocacy of the Small Business Admin-
istration.
VII. Congressional Review Act
Pursuant to the Congressional Review
Act (5 U.S.C. 801 et seq.), the Office of
Information and Regulatory Affairs des-
ignated this rule as not a “major rule,” as
defined by 5 U.S.C. 804(2).
Drafting Information
The principal author of these final
regulations is the Office of Associate
Chief Counsel (Passthroughs, Trusts, and
Estates). However, other personnel from
the Treasury Department and the IRS par-
ticipated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Amendments to the Regulations
Accordingly, the Treasury Depart-
ment and IRS 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 1.6050K-1 is amended
by:
1. Adding a heading for paragraph (c);
2. Revising the paragraph heading and
introductory text of paragraph (c)(1);
3. Revising paragraph (c)(1)(i);
4. Removing paragraph (c)(2) and
redesignating paragraph (c)(3) as new
paragraph (c)(2); and
5. Revising paragraph (h).
The addition and revisions read as fol-
lows:
§1.6050K-1 Returns relating to sales
or exchanges of certain partnership
interests.
* * * * *
(c) Statement to be furnished to trans-
feror and transferee—(1) In general.
Every partnership required to file a return
under paragraph (a) of this section must
furnish to each person whose name is
required to be set forth in such return a
written statement on or before January
31 of the calendar year following the cal-
endar year in which the section 751(a)
exchange occurred to which the return
under paragraph (a) relates (or, if later,
30 days after the partnership is notified
of the exchange as defined in paragraph
(e) of this section). The partnership must
use a copy of the Form 8308, filled out in
accordance with the instructions accom-
panying the form, as a statement unless
the Form 8308 contains information with
respect to more than one section 751(a)
exchange (see paragraph (a)(3) of this
section). If the partnership does not use
a copy of Form 8308 as a statement, the
statement shall include the information
required to be shown on Form 8308 with
respect to the section 751(a) exchange to
which the person to whom the statement
is furnished is a party. In addition, it shall
state that—
(i) The information shown on the state-
ment will be supplied to the Internal Rev-
enue Service,
* * * * *

Bulletin No. 2026–23 1561 June 1, 2026
(h) Applicability date. Paragraphs (c)
(1) introductory text and (c)(1)(i) of this
section apply to returns filed for taxable
years ending on or after May 20, 2026.
Paragraph (c)(2) of this section applies
to returns filed on or after November 30,
2020. Paragraph (d)(3) of this section
applies to transfers that occur on or after
November 30, 2020.
Frank J. Bisignano,
Chief Executive Officer.
Approved: April 29, 2026.
Kenneth J. Kies,
Assistant Secretary of the Treasury
(Tax Policy).
(Filed by the Office of the Federal Register May 19,
2026, 8:45 a.m., and published in the issue of the
Federal Register for May 20, 2026, 91 FR 29362.)

June 1, 2026 1562 Bulletin No. 2026–23
Part III
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2026-31
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month aver-
age segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the inter-
est rate on 30-year Treasury securities
under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to sin-
gle-employer plans (except for CSEC plans
under § 414(y)) pursuant to § 412. Section
430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under
this provision, present value is generally
determined using three 24-month average
interest rates (“segment rates”), each of
which applies to cash flows during speci-
fied periods. To the extent provided under
§ 430(h)(2)(C)(iv), these segment rates
are adjusted by the applicable percentage
of the 25-year average segment rates for
the period ending September 30 of the
year preceding the calendar year in which
the plan year begins.
1
However, an elec-
tion may be made under § 430(h)(2)(D)
(ii) to use the monthly yield curve in place
of the segment rates.
Section 1.430(h)(2)-1(d) provides
rules for determining the monthly cor-
porate bond yield curve, and § 1.430(h)
(2)-1(c) provides rules for determining
the 24-month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Con-
sistent with the methodology specified in
§ 1.430(h)(2)-1(d), the monthly corporate
bond yield curve derived from April 2026
data is in Table 2026-4 at the end of this
notice. The spot first, second, and third
segment rates for the month of April 2026
are, respectively, 4.27, 5.34, and 6.22.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) to be within the appli-
cable minimum and maximum percent-
ages of the corresponding 25-year aver-
age segment rates. Those percentages are
95% and 105% for plan years beginning
in 2025 and 2026. For this purpose, any
25-year average segment rate that is less
than 5% is deemed to be 5%. The 25-year
average segment rates for plan years
beginning in 2025 and 2026 were pub-
lished in Notice 2024-67, 2024-41 I.R.B.
726 and Notice 2025-47, 2025-40 I.R.B.
441, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for May
2026 without adjustment for the 25-year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable Month First Segment Second Segment Third Segment
May 2026 4.42 5.26 5.87
The adjusted 24-month average seg-
ment rates set forth in the chart below
reflect § 430(h)(2)(C)(iv) of the Code. The
24-month averages applicable for May
2026, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates in accordance with § 430(h)(2)
(C)(iv), are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2025May 20264.755.265.87
2026May 20264.755.255.87
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to multi-
employer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) pro-
vides that the interest rate used to calculate
current liability for this purpose must be
no more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year Trea-
1
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).

Bulletin No. 2026–23 1563 June 1, 2026
sury securities during the four-year period
ending on the last day before the beginning
of the plan year. Notice 88-73, 1988-2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The rate
of interest on 30-year Treasury securities
for April 2026 is 4.91 percent. The Service
determined this rate as the average of the
daily determinations of yield on the 30-year
Treasury bond maturing in February 2056.
For plan years beginning in May 2026, the
weighted average of the rates of interest on
30-year Treasury securities and the permis-
sible range of rates used to calculate current
liability are as follows:
Treasury Weighted Average Rates
For Plan Years Beginning In30-Year Treasury Weighted AveragePermissible Range 90% to 105%
May 20264.504.05 to 4.72
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Section 1.417(e)-1(d)(3) pro-
vides guidelines for determining the min-
imum present value segment rates. Pursu-
ant to that section, the minimum present
value segment rates determined for April
2026 are as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
April 2026 4.27 5.34 6.22
DRAFTING INFORMATION
The principal author of this notice
is Tom Morgan of the Office of Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Tony Montanaro at
626-927-1475 (not toll-free calls).

June 1, 2026 1564 Bulletin No. 2026–23
Table 2026-4
Monthly Yield Curve for April 2026
Derived from April 2026 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.54.0020.55.9040.56.2660.56.4080.56.46
1.04.0821.05.9141.06.2761.06.4081.06.46
1.54.1621.55.9341.56.2761.56.4081.56.46
2.04.2222.05.9542.06.2862.06.4082.06.47
2.54.2722.55.9642.56.2862.56.4082.56.47
3.04.3123.05.9843.06.2963.06.4183.06.47
3.54.3523.55.9943.56.2963.56.4183.56.47
4.04.3924.06.0044.06.2964.06.4184.06.47
4.54.4424.56.0144.56.3064.56.4184.56.47
5.04.4925.06.0345.06.3065.06.4185.06.47
5.54.5525.56.0445.56.3165.56.4285.56.47
6.04.6126.06.0546.06.3166.06.4286.06.48
6.54.6826.56.0646.56.3166.56.4286.56.48
7.04.7427.06.0747.06.3267.06.4287.06.48
7.54.8127.56.0847.56.3267.56.4287.56.48
8.04.8828.06.0948.06.3368.06.4288.06.48
8.54.9528.56.0948.56.3368.56.4388.56.48
9.05.0129.06.1049.06.3369.06.4389.06.48
9.55.0729.56.1149.56.3469.56.4389.56.48
10.05.1330.06.1250.06.3470.06.4390.06.48
10.55.1930.56.1350.56.3470.56.4390.56.48
11.05.2531.06.1451.06.3571.06.4491.06.49
11.55.3031.56.1551.56.3571.56.4491.56.49
12.05.3532.06.1652.06.3572.06.4492.06.49
12.55.4032.56.1652.56.3572.56.4492.56.49
13.05.4533.06.1753.06.3673.06.4493.06.49
13.55.4933.56.1853.56.3673.56.4493.56.49
14.05.5334.06.1954.06.3674.06.4494.06.49
14.55.5734.56.1954.56.3774.56.4594.56.49
15.05.6135.06.2055.06.3775.06.4595.06.49
15.55.6435.56.2155.56.3775.56.4595.56.49
16.05.6736.06.2156.06.3776.06.4596.06.49
16.55.7036.56.2256.56.3876.56.4596.56.50
17.05.7337.06.2257.06.3877.06.4597.06.50
17.55.7637.56.2357.56.3877.56.4597.56.50
18.05.7938.06.2458.06.3878.06.4698.06.50
18.55.8138.56.2458.56.3978.56.4698.56.50
19.05.8339.06.2559.06.3979.06.4699.06.50
19.55.8639.56.2559.56.3979.56.4699.56.50
20.05.8840.06.2660.06.3980.06.46100.06.50

Bulletin No. 2026–23 1565 June 1, 2026
2026 Cumulative List
of Changes in Plan
Qualification Requirements
for Defined Benefit
Qualified Pre-approved
Plans
Notice 2026-34
I. PURPOSE
This notice sets forth the 2026 Cumula-
tive List of Changes in Plan Qualification
Requirements for Defined Benefit Quali-
fied Pre-approved Plans (2026 Cumula-
tive List). The 2026 Cumulative List will
assist providers applying to the Internal
Revenue Service (IRS) for opinion letters
for the fourth remedial amendment cycle
for defined benefit qualified pre-approved
plans (Cycle 4) under the IRS’s pre-ap-
proved plan program. Cycle 4 began on
April 1, 2025. The Cycle 4 submission
period begins on August 1, 2026, and
ends on July 31, 2027. The 2026 Cumu-
lative List identifies recent changes in the
qualification requirements of the Internal
Revenue Code (Code) that were not taken
into account during the first three reme-
dial amendment cycles for defined bene-
fit qualified pre-approved plans and that
will be taken into account by the IRS with
respect to the form of a plan submitted to
the IRS for Cycle 4.
II. BACKGROUND
Under Rev. Proc. 2023-37, 2023-51
IRB 1491, every pre-approved plan has
a recurring remedial amendment cycle,
and a provider of a pre-approved plan
may apply for a new opinion letter for
the plan for each remedial amendment
cycle. Further, defined contribution qual-
ified pre-approved plans, defined benefit
qualified pre-approved plans, and sec-
tion 403(b) pre-approved plans all have
separate remedial amendment cycles. Part
III of Rev. Proc. 2023-37 sets forth the
procedures for a provider to apply for an
opinion letter for a pre-approved plan, as
well as the scope of reliance provided by
an opinion letter to adopting employers of
a provider’s pre-approved plan.
Pursuant to section 17 of Rev. Proc.
2023-37, the IRS publishes a cumulative
list for each remedial amendment cycle
to identify the recent changes in the qual-
ification requirements that will be taken
into account with respect to the form of
a pre-approved plan submitted to the IRS
for that remedial amendment cycle.
1
A
change in the qualification requirements
includes a statutory change or a change
in the requirements provided in regula-
tions or other guidance published in the
Internal Revenue Bulletin, without regard
to whether the change is required to be
reflected in plan terms or relates to an
optional provision that a provider could
choose to reflect in plan terms as a discre-
tionary amendment.
III. APPLICATION OF THE 2026
CUMULATIVE LIST
In section IV of this notice, the 2026
Cumulative List sets forth specific items
the IRS has identified for review in deter-
mining whether the form of a defined ben-
efit qualified pre-approved plan that has
been submitted to the IRS for a Cycle 4
opinion letter has been properly updated
since the plan was submitted for a Cycle 3
opinion letter.
2

Generally, the IRS will consider only
the items on the 2026 Cumulative List
in determining whether to issue a Cycle
4 opinion letter with respect to a defined
benefit qualified pre-approved plan, and
providers of pre-approved plans should not
include in plan documents submitted with
their Cycle 4 opinion letter applications
terms reflecting the provisions of legisla-
tion enacted or guidance issued after this
notice is issued. However, if a plan has not
been previously reviewed and is submit-
ted for Cycle 4 (or has been amended with
respect to previously approved language),
the IRS will also review the plan for items
on earlier Cumulative Lists,
3
as well as for
any other applicable qualification require-
ments that were considered by the IRS in
issuing opinion letters prior to the imple-
mentation of Cumulative Lists.
The list of changes in section IV of this
notice does not extend the deadline by
which a plan must be amended to com-
ply with any change in the qualification
requirements applicable to the plan. The
general deadline for timely adoption of
an interim or discretionary amendment is
provided in section 7 of Rev. Proc. 2023-
37. However, Q&A J-1 of Notice 2024-
2, 2024-2 IRB 316, provides additional
guidance with respect to the deadlines
for interim or discretionary amendments
adopted to reflect applicable provisions
of Division O of the Further Consolidated
Appropriations Act, 2020, Pub. L. 116-94,
133 Stat. 2534 (FCAA), known as the Set-
ting Every Community Up for Retirement
Enhancement Act of 2019 (SECURE Act),
section 104 of Division M of the FCAA,
known as the Bipartisan American Miners
Act of 2019 (Miners Act), section 2202 or
2203 of the Coronavirus Aid, Relief, and
Economic Security Act, Pub. L. 116-136,
134 Stat. 281 (2020) (CARES Act), as
modified by section 280 of the COVID-re-
lated Tax Relief Act of 2020, which was
enacted as Subtitle B, Title II, Division N,
of the Consolidated Appropriations Act,
2021, Pub. L. 116-260, 134 Stat. 1182
(2020) (CAA 2021), section 302 of Title
III of the Taxpayer Certainty and Disas-
ter Tax Relief Act of 2020 (Relief Act),
enacted as Division EE of CAA 2021, or
Division T of the Consolidated Appropria-
tions Act, 2023, Pub. L. 117-328, 136 Stat.
4459 (2022), known as the SECURE 2.0
Act of 2022 (SECURE 2.0 Act).
1
In order to be qualified, a defined benefit pre-approved plan must comply in operation with all applicable qualification requirements, not only those on the 2026 Cumulative List. To assist plan
providers in achieving operational compliance, the IRS provides an Operational Compliance List on its website that is updated periodically to identify changes in qualification requirements
that are effective during a calendar year. For the current Operational Compliance List, see https://www.irs.gov/retirement-plans/operational-compliance-list.
2
Consistent with previous Cumulative Lists, the 2026 Cumulative List does not include routine, ministerial guidance (such as guidance that is typically issued annually to announce a cost-
of-living adjustment to a qualified plan contribution limit).
3
For the items on earlier Cumulative Lists for defined benefit qualified pre-approved plans, see the 2020 Cumulative List, Notice 2020-14, 2020-13 IRB 555, and the 2012 Cumulative List,
Notice 2012-76, 2012-52 IRB 775.

June 1, 2026 1566 Bulletin No. 2026–23
IV. 2026 CUMULATIVE LIST OF
CHANGES IN PLAN QUALIFICATION
REQUIREMENTS FOR DEFINED
BENEFIT QUALIFIED PRE-
APPROVED PLANS
1. Section 401(a):
a. Required Minimum Distributions
(Section 401(a)(9))
i. Required beginning date
• Section 114 of the SECURE
Act amended section 401(a)(9)
(C)(i)(I) of the Code to increase
the age with respect to which
the required beginning date for
required minimum distributions
(RMDs) is determined from age
70½ to age 72 for employees
born on or after July 1, 1949, but
before January 1, 1951.
• Section 107 of the SECURE
2.0 Act amended section 401(a)
(9)(C) of the Code to increase
the age with respect to which
the required beginning date for
RMDs is determined from age
72 to age 73, for employees born
on or after January 1, 1951.
4
ii. Miscellaneous
• Section 401 of the SECURE Act
amended section 401(a)(9) of the
Code to provide new RMD rules
for designated beneficiaries.
• Final regulations under section
401(a)(9) of the Code that were
published on July 19, 2024 (89
FR 58886), provide guidance
relating to RMDs from defined
benefit plans that reflects the
amendments made to section
401(a)(9) by sections 114 and
401 of the SECURE Act and by
section 107 and other sections
of the SECURE 2.0 Act. These
regulations apply for purposes of
determining required minimum
distributions for calendar years
beginning on or after January 1,
2025.
5
• Notice 2023-54, 2023-31 IRB
383, provides relief with respect
to certain required minimum dis-
tributions for 2023.
b. Certain Involuntary Distributions
(Code Sections 401(a)(31)(B) and
411(a)(11))
• Section 304 of the SECURE 2.0
Act permits a plan to increase its
involuntary cashout limit from
$5,000 to $7,000.
c. Distributions During Working Retire-
ment (Code Section 401(a)(36))
• Section 104 of the Miners Act
amended section 401(a)(36) of
the Code to lower the minimum
age at which a pension plan
may make a distribution to an
employee who is not separated
from employment at the time of
the distribution. For plan years
beginning after December 31,
2019, the minimum age is low-
ered from age 62 to age 59½.
• Notice 2020-68, 2020-38 IRB
567, provides guidance with
respect to section 104 of the Min-
ers Act.
d. Forfeitures
• Proposed regulations under sec-
tion 401 of the Code that were
published on February 27, 2023
(88 FR 12282), would provide
rules relating to the use of for-
feitures in qualified retirement
plans. The proposed regulations
are proposed to apply for plan
years that begin on or after Jan-
uary 1, 2024, but, prior to the
applicability date of final regula-
tions, taxpayers may rely on the
proposed regulations.
e. Witnessing of Spousal Consent
• Proposed regulations under sec-
tion 401 of the Code that were
published on December 30, 2022
(87 FR 80501), would provide an
alternative to in-person witness-
ing of spousal consents required
to be witnessed by a notary pub-
lic or a plan representative and
would clarify that certain special
rules for the use of an electronic
medium for participant elections
also apply to spousal consents.
The regulations are proposed
to apply beginning on the date
that is six months after the pub-
lication of final regulations, but,
prior to the applicability date of
final regulations, taxpayers may
rely on the proposed regulations.
6
f. Modification of Nondiscrimination
Rules to Protect Older, Longer Ser-
vice Participants (Sections 401(a)
(26) and 401(o))
• Section 205 of the SECURE Act
added section 401(a)(26)(I) to
the Code to treat certain closed
or frozen defined benefit plans
as satisfying the section 401(a)
(26) minimum participation
requirements. Section 205 of the
SECURE Act also added section
401(o) to the Code to provide
special nondiscrimination testing
relief for plan sponsors seeking
to protect certain participants in
a closed defined benefit plan. In
addition, section 401(o)(2) per-
mits nondiscrimination testing
relief where a sponsor provides
certain “make-whole” contribu-
tions to a defined contribution
plan.
2. Section 401(b):
• Section 316 of the SECURE
2.0 Act amended section 401(b)
of the Code to provide that if
an employer amends a plan to
increase accrued benefits effec-
tive as of any date during the
immediately preceding plan
year, the amendment would not
otherwise cause the plan to fail
to meet any of the qualification
requirements, and the amend-
ment is adopted before the time
4
Section 107 of the SECURE 2.0 Act includes a provision increasing the age with respect to which the required beginning date for RMDs is determined to age 75. This increase will not
affect the timing of RMDs until after the end of Cycle 4 for defined benefit qualified pre-approved plans. Accordingly, the IRS will not review plan documents submitted for Cycle 4 for that
provision.
5
Proposed regulations under section 401(a)(9) that were published on February 24, 2022 (87 FR 10504), would provide guidance relating to RMDs from defined benefit plans that reflects the
amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely
on a good faith, reasonable interpretation of the amendments made by sections 114 and 401 of the SECURE Act to which the final regulations relate. Compliance with the proposed regulations
is considered reliance on a good faith, reasonable interpretation of the amendments made by sections 114 and 401 of the SECURE Act to which the final regulations relate.
6
The IRS expects that most plans will not need to be amended to reflect these proposed regulations relating to the witnessing of spousal consent, as most plans will not include language that
contradicts these proposed regulations.

Bulletin No. 2026–23 1567 June 1, 2026
prescribed by law for filing the
return of the employer for the
taxable year (including exten-
sions) that includes the effective
date of the amendment, then
the employer may elect to treat
the amendment as having been
adopted as of the last day of the
plan year in which it is effective.
3. Sections 402 and 402A:
• Section 41104 of the Bipartisan
Budget Act of 2018, Pub. L. 115-
123, 132 Stat. 64, added section
6343(f) of the Code to hold an
individual harmless in the case
of a wrongful levy upon an eligi-
ble retirement plan. The eligible
retirement plan may permit the
re-contribution of any property
or money returned to the indi-
vidual as a result of the wrongful
levy, and such contribution will
be treated as a rollover under sec-
tion 402(c) or section 402A(c)
(3), as applicable.
• Final regulations under section
402(c) that were published on
July 19, 2024, amend the rules
relating to eligible rollover dis-
tributions from defined benefit
plans. These regulations apply
for distributions on or after Jan-
uary 1, 2025.
7
4. Section 402(l):
• Section 328 of the SECURE 2.0
Act amended section 402(l)(5)
(A) of the Code to permit gov-
ernmental plans to make direct
distributions to certain eligible
retired public safety officers of
amounts necessary to pay for
qualified health insurance premi-
ums.
5. Section 411:
a. Partial Terminations
• Section 209 of the Relief Act
provides temporary guidance
relating to partial plan termina-
tions.
8
b. Cash Balance Plans
• Under section 348 of the
SECURE 2.0 Act, a cash balance
plan that provides for pay cred-
its to participants that increase
with a participant’s age or ser-
vice and provides for a variable
interest crediting rate no lon-
ger risks violating the accrual
requirements of section 411(b)
(1) of the Code if that interest
crediting rate falls below a cer-
tain point. Section H of Notice
2024-2 provides guidance with
respect to the application of sec-
tion 501 of the SECURE 2.0 Act
for amendments made pursuant
to section 348 of the SECURE
2.0 Act.
6. Sections 411 and 417:
• Final regulations under sec-
tions 411 and 417 of the Code
that were published on January
19, 2024 (89 FR 3552), provide
guidance relating to the mini-
mum present value requirements
applicable to certain defined
benefit pension plans. The reg-
ulations provide guidance on
changes made by the Pension
Protection Act of 2006, Pub.
L. 109-280, 120 Stat. 780, to
the prescribed interest rate and
mortality table and other guid-
ance, including rules regarding
the treatment of preretirement
mortality discounts and Social
Security level income options.
7. Section 414:
• Section 315 of the SECURE
2.0 Act amended section 414 of
the Code to eliminate automatic
attribution of ownership between
spouses with separate busi-
nesses in community property
states, and to modify the attribu-
tion rules regarding ownership
between parents and minor chil-
dren, for purposes of applying
the rules relating to a controlled
group of corporations under sec-
tion 414(b) or an affiliated ser-
vice group under section 414(m).
• Final regulations that were pub-
lished on December 30, 2024 (89
FR 106848) extend the partner-
ship and trust attribution rules
to the determination of whether
a parent-subsidiary controlled
group exists under section 414(c)
(trades or businesses under com-
mon control). The change applies
to plan years beginning on or
after January 1, 2025.
8. Section 414(p):
• Section 339 of the SECURE
2.0 Act amended the definition
of “domestic relations order”
in section 414(p)(1)(B) of the
Code to include a domestic rela-
tions order issued pursuant to an
Indian tribal domestic relations
law.
9. Section 415(b):
• Section 119 of the SECURE 2.0
Act amended the limitations in
section 415(b) for certain partic-
ipants in an eligible rural electric
cooperative plan.
10. Section 420:
• Section 606 of the SECURE 2.0
Act amended section 420 of the
Code to provide that a qualified
transfer of excess pension assets
of a defined benefit plan may be
made to a retiree medical account
or life insurance account within
the plan until December 31,
2032, rather than December 31,
2025. Section 420, as amended,
also provides a rule for de mini-
mis transfers.
11. Sections 430 and 436:
• Section 3609 of the CARES Act
added section 414(y)(1)(D) to
the Code. Section 414(y)(1)(D)
provides that a cooperative and
small employer charity pension
plan (CSEC plan) is defined to
include a defined benefit plan
that, as of January 1, 2000, was
maintained by a tax-exempt
employer that met specific char-
acteristics. A CSEC plan, as
defined in section 414(y), is not
permitted to include the benefit
restrictions of section 436.
7
Proposed regulations under section 402(c) that were published on February 24, 2022, would amend the rules relating to eligible rollover distributions from defined benefit plans. Under
the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the statutory amendments to which the final
regulations relate. Compliance with the proposed regulations is considered reliance on a good faith, reasonable interpretation of the statutory amendments to which the final regulations relate.
8
The IRS expects that most plans will not need to be amended to reflect section 209 of the Relief Act, as most plans will not include language contradicting it.

June 1, 2026 1568 Bulletin No. 2026–23
12. Disaster-related Rules:
• Section 202 of the Taxpayer Cer-
tainty and Disaster Tax Relief
Act of 2019, enacted as Division
Q of the FCAA, provides special
disaster-related rules for use of
retirement funds.
• Section 2202 of the CARES Act,
as modified by section 280 of Divi-
sion N of the CAA 2021, provides
special rules for coronavirus-re-
lated distributions and plan loans
made to qualified individuals.
• Notice 2020-50, 2020-28 IRB
35, provides guidance relating to
the application of section 2202
of the CARES Act for qualified
individuals and eligible retire-
ment plans.
• Section 302 of the Relief Act
provides special disaster-related
rules for use of retirement funds.
• Section 331 of the SECURE 2.0
Act provides permanent special
rules governing plan distribu-
tions, recontributions, and loans
to participants affected by qual-
ified federally declared major
disasters.
V. DRAFTING INFORMATION
The principal author of this notice is
the Office of Associate Chief Counsel
(Employee Benefits, Exempt Organiza-
tions, and Employment Taxes). For further
information regarding this notice, contact
Employee Plans at (513) 975-6319 (not a
toll-free number).

Bulletin No. 2026–23 1569 June 1, 2026
Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2026-10
Table of Contents
The Internal Revenue Service has
revoked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section 170(c)
(2) if the organization has not timely filed
a suit for declaratory judgment under sec-
tion 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declar-
atory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will con-
tinue to be deductible. Protection under
section 7428(c) would begin on May 13,
2026, and would end on the date the court
first determines the organization is not
described in section 170(c)(2) as more
particularly set for in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
Name Of OrganizationEffective Date of RevocationLocation
Societe Jacques Cartier Cercle No. 401/01/2023Pawtucket, RI
National Alliance on Mental Illness01/01/2022Kingston, PA
Philantrepreneur01/01/2022Rocklin, CA
Les Cheneaux Pure Water Inc12/31/2022Petoskey, MI
Les Cheneaux Pure Water Inc12/31/2022Mackinac Island, MI
Upper Room of Erie03/01/2023Erie, PA

Bulletin No. 2026–23 i June 1, 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 1, 2026 ii Bulletin No. 2026–23
Numerical Finding List
1
Bulletin 2026–23
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
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
Proposed Regulations:—Continued
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
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
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
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
Treasury Decisions:—Continued
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. 2026–23 iii June 1, 2026
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2026–23
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
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.
We Welcome Comments About the Internal Revenue Bulletin
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
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