us-irs-revenue-rulings-irb-2026-36-pdf•Internal Revenue Bulletin 2026-36 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2026-36 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2026-36-pdfInternal Revenue Bulletin 2026-36 (PDF rendition): IRS Revenue RulingsGuidance
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Bulletin No. 2026–36 August 31, 2026 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. ADMINISTRATIVE Rev. Rul. 2026-15, page 216. Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the cal- endar quarter beginning October 1, 2026, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 per- cent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a cor- porate overpayment exceeding $10,000 will be 4.5 percent. T.D. 10053, page 237. These final regulations amend regulations under section 3406 to change the threshold for when certain third party settle- ment organizations (TPSOs) are required to perform backup withholding. These final regulations clarify that in the case of certain payments made through third parties, the amount sub- ject to backup withholding under section 3406 is determined by taking into account the exception for de minimis payments by TPSOs in section 6050W(e). These final regulations also clarify the amount subject to backup withholding and clarify situations when the threshold does not apply. The final regula- tions reflect recent changes to the statutory law. INCOME TAX Notice 2026-50, page 242. This notice provides interim guidance, pending the issuance of regulations, relating to the credit for carbon oxide seques- tration under section 45Q of the Internal Revenue Code to reflect the Environmental Protection Agency’s proposed regulations to amend the Greenhouse Gas Reporting Pro- gram to remove reporting obligations imposed under sub- part RR of 40 CFR part 98. See 90 F.R. 44591 (Sept. 16, 2025). This notice modifies and amplifies Notice 2026-1 by expanding the scope of the safe harbor provided in Notice 2026-1 to include qualified carbon oxide that is used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project and the determination of the amount of qualified carbon oxide subject to recapture. This notice also extends the applicability date of the safe harbor provided in Notice 2026-1. Rev. Rul. 2026-16, page 237. The revenue ruling holds that ICE Endex, a regulated exchange of the Netherlands, is a “qualified board or exchange” within the meaning of section 1256(g)(7)(C). 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. August 31, 2026 Bulletin No. 2026–36 Part I Section 6621.— Determination of Rate of Interest 26 CFR 301.6621-1: Interest rate. Rev. Rul. 2026-15 Section 6621 of the Internal Reve- nue Code establishes the interest rates on overpayments and underpayments of tax. Under section 6621(a)(1), the over- payment rate is the sum of the federal short-term rate plus 3 percentage points (2 percentage points in the case of a corpo- ration), except the rate for the portion of a corporate overpayment of tax exceeding $10,000 for a taxable period is the sum of the federal short-term rate plus 0.5 of a percentage point. Under section 6621(a) (2), the underpayment rate is the sum of the federal short-term rate plus 3 percent- age points. Section 6621(c) provides that for pur- poses of interest payable under section 6601 on any large corporate underpay- ment, the underpayment rate under section 6621(a)(2) is determined by substituting “5 percentage points” for “3 percentage points.” See section 6621(c) and section 301.6621-3 of the Regulations on Proce- dure and Administration for the definition of a large corporate underpayment and for the rules for determining the appli- cable date. Section 6621(c) and section 301.6621-3 are generally effective for periods after December 31, 1990. Section 6621(b)(1) provides that the Secretary will determine the federal short- term rate for the first month in each cal- endar quarter. Section 6621(b)(2)(A) provides that the federal short-term rate determined under section 6621(b)(1) for any month applies during the first calen- dar quarter beginning after that month. Section 6621(b)(3) provides that the fed- eral short-term rate for any month is the federal short-term rate determined during that month by the Secretary in accordance with section 1274(d), rounded to the near- est full percent (or, if a multiple of 1/2 of 1 percent, the rate is increased to the next highest full percent). Notice 88-59, 1988-1 C.B. 546, announced that in determining the quar- terly interest rates to be used for overpay- ments and underpayments of tax under section 6621, the Internal Revenue Ser- vice will use the federal short-term rate based on daily compounding because that rate is most consistent with section 6621 which, pursuant to section 6622, is subject to daily compounding. The federal short-term rate deter- mined in accordance with section 1274(d) during July 2026 is the rate pub- lished in Revenue Ruling 2026-13, 2026- 32 IRB 132, to take effect beginning August 1, 2026. The federal short-term rate, rounded to the nearest full percent, based on daily compounding determined during the month of July 2026 is 4 per- cent. Accordingly, an overpayment rate of 7 percent (6 percent in the case of a corporation) and an underpayment rate of 7 percent are established for the calendar quarter beginning October 1, 2026. The overpayment rate for the portion of a cor- porate overpayment exceeding $10,000 for the calendar quarter beginning Octo- ber 1, 2026, is 4.5 percent. The underpay- ment rate for large corporate underpay- ments for the calendar quarter beginning October 1, 2026, is 9 percent. These rates apply to amounts bearing interest during that calendar quarter. Sections 6654(a)(1) and 6655(a) (1) provide that the underpayment rate established under section 6621 applies in determining the addition to tax under sections 6654 and 6655 for failure to pay estimated tax for any taxable year. Thus, the 7 percent rate also applies to estimated tax underpayments for the fourth calen- dar quarter beginning October 1, 2026. In addition, pursuant to section 6603(d) (4), the rate of interest on section 6603 deposits is 4 percent for the fourth calen- dar quarter in 2026. Interest factors for daily compound interest for annual rates of 4.5 percent, 6 percent, 7 percent and 9 percent are pub- lished in Tables 14, 17, 19 and 23 of Rev. Proc. 95-17, 1995-1 C.B. 566, 569, 571, and 575. Annual interest rates to be compounded daily pursuant to section 6622 that apply for prior periods are set forth in the tables accompanying this revenue ruling. DRAFTING INFORMATION The principal author of this revenue ruling is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). For further informa- tion regarding this revenue ruling, contact Mr. Conrad at (202) 317-6844 (not a toll- free number). August 31, 2026 216 Bulletin No. 2026–36 Bulletin No. 2026–36 217 August 31, 2026 365 Day Year 0.5% Compound Rate 184 Days DaysFactorDaysFactorDaysFactor 10.000013699630.0008633801250.001713784 20.000027397640.0008770911260.001727506 30.000041096650.0008908011270.001741228 40.000054796660.0009045121280.001754951 50.000068495670.0009182231290.001768673 60.000082195680.0009319341300.001782396 70.000095894690.0009456461310.001796119 80.000109594700.0009593571320.001809843 90.000123294710.0009730691330.001823566 100.000136995720.0009867811340.001837290 110.000150695730.0010004931350.001851013 120.000164396740.0010142061360.001864737 130.000178097750.0010279181370.001878462 140.000191798760.0010416311380.001892186 150.000205499770.0010553441390.001905910 160.000219201780.0010690571400.001919635 170.000232902790.0010827701410.001933360 180.000246604800.0010964841420.001947085 190.000260306810.0011101971430.001960811 200.000274008820.0011239111440.001974536 210.000287711830.0011376251450.001988262 220.000301413840.0011513391460.002001988 230.000315116850.0011650541470.002015714 240.000328819860.0011787681480.002029440 250.000342522870.0011924831490.002043166 260.000356225880.0012061981500.002056893 270.000369929890.0012199131510.002070620 280.000383633900.0012336291520.002084347 290.000397336910.0012473441530.002098074 300.000411041920.0012610601540.002111801 310.000424745930.0012747761550.002125529 320.000438449940.0012884921560.002139257 330.000452154950.0013022081570.002152985 340.000465859960.0013159251580.002166713 350.000479564970.0013296411590.002180441 360.000493269980.0013433581600.002194169 370.000506974990.0013570751610.002207898 380.0005206801000.0013707921620.002221627 390.0005343861010.0013845101630.002235356 400.0005480921020.0013982271640.002249085 410.0005617981030.0014119451650.002262815 420.0005755041040.0014256631660.002276544 August 31, 2026 218 Bulletin No. 2026–36 430.0005892111050.0014393811670.002290274 440.0006029171060.0014531001680.002304004 450.0006166241070.0014668181690.002317734 460.0006303311080.0014805371700.002331465 470.0006440391090.0014942561710.002345195 480.0006577461100.0015079751720.002358926 490.0006714541110.0015216941730.002372657 500.0006851611120.0015354141740.002386388 510.0006988691130.0015491331750.002400120 520.0007125781140.0015628531760.002413851 530.0007262861150.0015765731770.002427583 540.0007399951160.0015902931780.002441315 550.0007537031170.0016040141790.002455047 560.0007674121180.0016177341800.002468779 570.0007811211190.0016314551810.002482511 580.0007948311200.0016451761820.002496244 590.0008085401210.0016588971830.002509977 600.0008222501220.0016726191840.002523710 610.0008359601230.001686340 620.0008496701240.001700062 Bulletin No. 2026–36 219 August 31, 2026 366 Day Year 0.5% Compound Rate 184 Days DaysFactorDaysFactorDaysFactor 10.000013661630.0008610201250.001709097 20.000027323640.0008746931260.001722782 30.000040984650.0008883661270.001736467 40.000054646660.0009020401280.001750152 50.000068308670.0009157131290.001763837 60.000081970680.0009293871300.001777522 70.000095632690.0009430611310.001791208 80.000109295700.0009567351320.001804893 90.000122958710.0009704091330.001818579 100.000136620720.0009840841340.001832265 110.000150283730.0009977581350.001845951 120.000163947740.0010114331360.001859638 130.000177610750.0010251081370.001873324 140.000191274760.0010387831380.001887011 150.000204938770.0010524591390.001900698 160.000218602780.0010661341400.001914385 170.000232266790.0010798101410.001928073 180.000245930800.0010934861420.001941760 190.000259595810.0011071621430.001955448 200.000273260820.0011208391440.001969136 210.000286924830.0011345151450.001982824 220.000300590840.0011481921460.001996512 230.000314255850.0011618691470.002010201 240.000327920860.0011755461480.002023889 250.000341586870.0011892231490.002037578 260.000355252880.0012029001500.002051267 270.000368918890.0012165781510.002064957 280.000382584900.0012302561520.002078646 290.000396251910.0012439341530.002092336 300.000409917920.0012576121540.002106025 310.000423584930.0012712911550.002119715 320.000437251940.0012849691560.002133405 330.000450918950.0012986481570.002147096 340.000464586960.0013123271580.002160786 350.000478253970.0013260061590.002174477 360.000491921980.0013396851600.002188168 370.000505589990.0013533651610.002201859 380.0005192571000.0013670441620.002215550 390.0005329251010.0013807241630.002229242 400.0005465941020.0013944041640.002242933 410.0005602621030.0014080851650.002256625 420.0005739311040.0014217651660.002270317 August 31, 2026 220 Bulletin No. 2026–36 430.0005876001050.0014354461670.002284010 440.0006012691060.0014491271680.002297702 450.0006149391070.0014628081690.002311395 460.0006286081080.0014764891700.002325087 470.0006422781090.0014901701710.002338780 480.0006559481100.0015038521720.002352473 490.0006696181110.0015175331730.002366167 500.0006832891120.0015312151740.002379860 510.0006969591130.0015448971750.002393554 520.0007106301140.0015585801760.002407248 530.0007243011150.0015722621770.002420942 540.0007379721160.0015859451780.002434636 550.0007516431170.0015996281790.002448331 560.0007653151180.0016133111800.002462025 570.0007789861190.0016269941810.002475720 580.0007926581200.0016406781820.002489415 590.0008063301210.0016543611830.002503110 600.0008200031220.0016680451840.002516806 610.0008336751230.001681729 620.0008473481240.001695413 Bulletin No. 2026–36 221 August 31, 2026 TABLE OF INTEREST RATES PERIODS BEFORE JUL. 1, 1975 – PERIODS ENDING DEC. 31, 1986 OVERPAYMENTS AND UNDERPAYMENTS PERIODRATEIn 1995–1 C.B. DAILY RATE TABLE Before Jul. 1, 19756%Table2,pg.557 Jul. 1, 1975–Jan. 31, 19769%Table4,pg.559 Feb. 1, 1976–Jan. 31, 19787%Table3,pg.558 Feb. 1, 1978–Jan. 31, 19806%Table2,pg.557 Feb. 1, 1980–Jan. 31, 198212%Table5,pg.560 Feb. 1, 1982–Dec. 31, 198220%Table6,pg.560 Jan. 1, 1983–Jun. 30, 198316%Table37,pg.591 Jul. 1, 1983–Dec. 31, 198311%Table27,pg.581 Jan. 1, 1984–Jun. 30, 198411%Table75,pg.629 Jul. 1, 1984–Dec. 31, 198411%Table75,pg.629 Jan. 1, 1985–Dec. 31, 198513%Table31,pg.585 Jul. 1, 1985–Dec. 31, 198511%Table27,pg.581 Jan. 1, 1986–Jun. 30, 198610%Table25,pg.579 Jul. 1, 1986–Dec. 31, 19869%Table23,pg.577 TABLE OF INTEREST RATES FROM JAN. 1, 1987 – Dec. 31, 1998 OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE RATETABLEPGRATETABLEPG Jan. 1, 1987–Mar. 31, 19878%215759%23577 Apr. 1, 1987–Jun. 30, 19878%215759%23577 Jul. 1, 1987–Sep. 30, 19878%215759%23577 Oct. 1, 1987–Dec. 31, 19879%2357710%25579 Jan. 1, 1988–Mar. 31, 198810%7362711%75629 Apr. 1, 1988–Jun. 30, 19889%7162510%73627 Jul. 1, 1988–Sep. 30, 19889%7162510%73627 Oct. 1, 1988–Dec. 31, 198810%7362711%75629 Jan. 1, 1989–Mar. 31, 198910%2557911%27581 Apr. 1, 1989–Jun. 30, 198911%2758112%29583 Jul. 1, 1989–Sep. 30, 198911%2758112%29583 Oct. 1, 1989–Dec. 31, 198910%2557911%27581 Jan. 1, 1990–Mar. 31, 199010%2557911%27581 Apr. 1, 1990–Jun. 30, 199010%2557911%27581 Jul. 1, 1990–Sep. 30, 199010%2557911%27581 Oct. 1, 1990–Dec. 31, 199010%2557911%27581 Jan. 1, 1991–Mar. 31, 199110%2557911%27581 Apr. 1, 1991–Jun. 30, 19919%2357710%25579 Jul. 1, 1991–Sep. 30, 19919%2357710%25579 Oct. 1, 1991–Dec. 31, 19919%2357710%25579 Jan. 1, 1992–Mar. 31, 19928%696239%71625 August 31, 2026 222 Bulletin No. 2026–36 Apr. 1, 1992–Jun. 30, 19927%676218%69623 Jul. 1, 1992–Sep. 30, 19927%676218%69623 Oct. 1, 1992–Dec. 31, 19926%656197%67621 Jan. 1, 1993–Mar. 31, 19936%175717%19573 Apr. 1, 1993–Jun. 30, 19936%175717%19573 Jul. 1, 1993–Sep. 30, 19936%175717%19573 Oct. 1, 1993–Dec. 31, 19936%175717%19573 Jan. 1, 1994–Mar. 31, 19946%175717%19573 Apr. 1, 1994–Jun. 30, 19946%175717%19573 Jul. 1, 1994–Sep. 30, 19947%195738%21575 Oct. 1, 1994–Dec. 31, 19948%215759%23577 Jan. 1, 1995–Mar. 31, 19958%215759%23577 Apr. 1, 1995–Jun. 30, 19959%2357710%25579 Jul. 1, 1995–Sep. 30, 19958%215759%23577 Oct. 1, 1995–Dec. 31, 19958%215759%23577 Jan. 1, 1996–Mar. 31, 19968%696239%71625 Apr. 1, 1996–Jun. 30, 19967%676218%69623 Jul. 1, 1996–Sep. 30, 19968%696239%71625 Oct. 1, 1996–Dec. 31, 19968%696239%71625 Jan. 1, 1997–Mar. 31, 19978%215759%23577 Apr. 1, 1997–Jun. 30, 19978%215759%23577 Jul. 1, 1997–Sep. 30, 19978%215759%23577 Oct. 1, 1997–Dec. 31, 19978%215759%23577 Jan. 1, 1998–Mar. 31, 19988%215759%23577 Apr. 1, 1998–Jun. 30, 19987%195738%21575 Jul. 1, 1998–Sep. 30, 19987%195738%21575 Oct. 1, 1998–Dec. 31, 19987%195738%21575 Bulletin No. 2026–36 223 August 31, 2026 TABLE OF INTEREST RATES FROM JANUARY 1, 1999 – PRESENT NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS 1995–1 C.B. RATETABLEPAGE Jan. 1, 1999–Mar. 31, 19997%19573 Apr. 1, 1999–Jun. 30, 19998%21575 Jul. 1, 1999–Sep. 30, 19998%21575 Oct. 1, 1999–Dec. 31, 19998%21575 Jan. 1, 2000–Mar. 31, 20008%69623 Apr. 1, 2000–Jun. 30, 20009%71625 Jul. 1, 2000–Sep. 30, 20009%71625 Oct. 1, 2000–Dec. 31, 20009%71625 Jan. 1, 2001–Mar. 31, 20019%23577 Apr. 1, 2001–Jun. 30, 20018%21575 Jul. 1, 2001–Sep. 30, 20017%19573 Oct. 1, 2001–Dec. 31, 20017%19573 Jan. 1, 2002–Mar. 31, 20026%17571 Apr. 1, 2002–Jun. 30, 20026%17571 Jul. 1, 2002–Sep. 30, 20026%17571 Oct. 1, 2002–Dec. 31, 20026%17571 Jan. 1, 2003–Mar. 31, 20035%15569 Apr. 1, 2003–Jun. 30, 20035%15569 Jul. 1, 2003–Sep. 30, 20035%15569 Oct. 1, 2003–Dec. 31, 20034%13567 Jan. 1, 2004–Mar. 31, 20044%61615 Apr. 1, 2004–Jun. 30, 20045%63617 Jul. 1, 2004–Sep. 30, 20044%61615 Oct. 1, 2004–Dec. 31, 20045%63617 Jan. 1, 2005–Mar. 31, 20055%15569 Apr. 1, 2005–Jun. 30, 20056%17571 Jul. 1, 2005–Sep. 30, 20056%17571 Oct. 1, 2005–Dec. 31, 20057%19573 Jan. 1, 2006–Mar. 31, 20067%19573 Apr. 1, 2006–Jun. 30, 20067%19573 Jul. 1, 2006–Sep. 30, 20068%21575 Oct. 1, 2006–Dec. 31, 20068%21575 Jan. 1, 2007–Mar. 31, 20078%21575 Apr. 1, 2007–Jun. 30, 20078%21575 Jul. 1, 2007–Sep. 30, 20078%21575 Oct. 1, 2007–Dec. 31, 20078%21575 Jan. 1, 2008–Mar. 31, 20087%67621 Apr. 1, 2008–Jun. 30, 20086%65619 Jul. 1, 2008–Sep. 30, 20085%63617 Oct. 1, 2008–Dec. 31, 20086%65619 Jan. 1, 2009–Mar. 31, 20095%15569 August 31, 2026 224 Bulletin No. 2026–36 Apr. 1, 2009–Jun. 30, 20094%13567 Jul. 1, 2009–Sep. 30, 20094%13567 Oct. 1, 2009–Dec. 31, 20094%13567 Jan. 1, 2010–Mar. 31, 20104%13567 Apr. 1, 2010–Jun. 30, 20104%13567 Jul. 1, 2010–Sep. 30, 20104%13567 Oct. 1, 2010–Dec. 31, 20104%13567 Jan. 1, 2011–Mar. 31, 20113%11565 Apr. 1, 2011–Jun. 30, 20114%13567 Jul. 1, 2011–Sep. 30, 20114%13567 Oct. 1, 2011–Dec. 31, 20113%11565 Jan. 1, 2012–Mar. 31, 20123%59613 Apr. 1, 2012–Jun. 30, 20123%59613 Jul. 1, 2012–Sep. 30, 20123%59613 Oct. 1, 2012–Dec. 31, 20123%59613 Jan. 1, 2013–Mar. 31, 20133%11565 Apr. 1, 2013–Jun. 30, 20133%11565 Jul. 1, 2013–Sep. 30, 20133%11565 Oct. 1, 2013–Dec. 31, 20133%11565 Jan. 1, 2014–Mar. 31, 20143%11565 Apr. 1, 2014–Jun. 30, 20143%11565 Jul. 1, 2014–Sep. 30, 20143%11565 Oct. 1, 2014–Dec. 31, 20143%11565 Jan. 1, 2015–Mar. 31, 20153%11565 Apr. 1, 2015–Jun. 30, 20153%11565 Jul. 1, 2015–Sep. 30, 20153%11565 Oct. 1, 2015–Dec. 31, 20153%11565 Jan. 1, 2016–Mar. 31, 20163%59613 Apr. 1, 2016–Jun. 30, 20164%61615 Jul. 1, 2016–Sep. 30, 20164%61615 Oct. 1, 2016–Dec. 31, 20164%61615 Jan. 1, 2017–Mar. 31, 20174%13567 Apr. 1, 2017–Jun. 30, 20174%13567 Jul. 1, 2017–Sep. 30, 20174%13567 Oct. 1, 2017–Dec. 31, 20174%13567 Jan. 1, 2018–Mar. 31, 20184%13567 Apr. 1, 2018–Jun. 30, 20185%15569 Jul. 1, 2018–Sep. 30, 20185%15569 Oct. 1, 2018–Dec. 31, 20185%15569 Jan. 1, 2019–Mar. 31, 20196%17571 Apr. 1, 2019–Jun. 30, 20196%17571 Jul. 1, 2019–Sep. 30, 20195%15569 Oct. 1, 2019–Dec. 31, 20195%15569 Jan. 1, 2020–Mar. 31, 20205%63617 Apr. 1, 2020–Jun. 30, 20205%63617 Bulletin No. 2026–36 225 August 31, 2026 Jul. 1, 2020–Sep. 30, 20203%59613 Oct. 1, 2020–Dec. 31, 20203%59613 Jan. 1, 2021–Mar. 31, 20213%11565 Apr. 1, 2021–Jun. 30, 20213%11565 Jul. 1, 2021–Sep. 30, 20213%11565 Oct. 1, 2021–Dec. 31, 20213%11565 Jan. 1, 2022–Mar. 31, 20223%11565 Apr. 1, 2022–Jun. 30, 20224%13567 Jul. 1, 2022–Sep. 30, 20225%15569 Oct. 1, 2022–Dec. 31, 20226%17571 Jan. 1, 2023–Mar. 31, 20237%19573 Apr. 1, 2023–Jun. 30, 20237%19573 Jul. 1, 2023–Sep. 30, 2023 7%19573 Oct. 1, 2023–Dec. 31, 20238%21575 Jan. 1, 2024–Mar. 31, 20248%69623 Apr. 1, 2024–Jun. 30, 20248%69623 Jul. 1, 2024–Sep. 30, 20248%69623 Oct. 1, 2024–Dec. 31, 20248%69623 Jan. 1, 2025–Mar. 31, 20257%19573 Apr. 1, 2025–Jun. 30, 20257%19573 Jul. 1, 2025–Sep. 30, 20257%19573 Oct. 1, 2025–Dec. 31, 20257%19573 Jan. 1, 2026–Mar. 31, 20267%19573 Apr. 1, 2026–Jun. 30, 20266%17571 Jul. 1, 2026–Sep. 30, 20267%19573 Oct. 1, 2026–Dec. 31, 20267%19573 August 31, 2026 226 Bulletin No. 2026–36 TABLE OF INTEREST RATES FROM JANUARY 1, 1999 – PRESENT CORPORATE OVERPAYMENTS AND UNDERPAYMENTS OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATETABLEPGRATETABLEPG Jan. 1, 1999–Mar. 31, 19996%175717%19573 Apr. 1, 1999–Jun. 30, 19997%195738%21575 Jul. 1, 1999–Sep. 30, 19997%195738%21575 Oct. 1, 1999–Dec. 31, 19997%195738%21575 Jan. 1, 2000–Mar. 30, 20007%676218%69623 Apr. 1, 2000–Jun. 30, 20008%696239%71625 Jul. 1, 2000–Sep. 30, 20008%696239%71625 Oct. 1, 2000–Dec. 31, 20008%696239%71625 Jan. 1, 2001–Mar. 31, 20018%215759%23577 Apr. 1, 2001–Jun. 30, 20017%195738%21575 Jul. 1, 2001–Sep. 30, 20016%175717%19573 Oct. 1, 2001–Dec. 31, 20016%175717%19573 Jan. 1, 2002–Mar. 31, 20025%155696%17571 Apr. 1, 2002–Jun. 30, 20025%155696%17571 Jul. 1, 2002–Sep. 30, 20025%155696%17571 Oct. 1, 2002–Dec. 31, 20025%155696%17571 Jan. 1, 2003–Mar. 31, 20034%135675%15569 Apr. 1, 2003–Jun. 30, 20034%135675%15569 Jul. 1, 2003–Sep. 30, 20034%135675%15569 Oct. 1, 2003–Dec. 31, 20033%115654%13567 Jan. 1, 2004–Mar. 31, 20043%596134%61615 Apr. 1, 2004–Jun. 30, 20044%616155%63617 Jul. 1, 2004–Sep. 30, 20043%596134%61615 Oct. 1, 2004–Dec. 31, 20044%616155%63617 Jan. 1, 2005–Mar. 31, 20054%135675%15569 Apr. 1, 2005–Jun. 30, 20055%155696%17571 Jul. 1, 2005–Sep. 30, 20055%155696%17571 Oct. 1, 2005–Dec. 31, 20056%175717%19573 Jan. 1, 2006–Mar. 31, 20066%175717%19573 Apr. 1, 2006–Jun. 30, 20066%175717%19573 Jul. 1, 2006–Sep. 30, 20067%195738%21575 Oct. 1, 2006–Dec. 31, 20067%195738%21575 Jan. 1, 2007–Mar. 31, 20077%195738%21575 Apr. 1, 2007–Jun. 30, 20077%195738%21575 Jul. 1, 2007–Sep. 30, 20077%195738%21575 Oct. 1, 2007–Dec. 31, 20077%195738%21575 Jan. 1, 2008–Mar. 31, 20086%656197%67621 Apr. 1, 2008–Jun. 30, 20085%636176%65619 Jul. 1, 2008–Sep. 30, 20084%616155%63617 Oct. 1, 2008–Dec. 31, 20085%636176%65619 Bulletin No. 2026–36 227 August 31, 2026 Jan. 1, 2009–Mar. 31, 20094%135675%15569 Apr. 1, 2009–Jun. 30, 20093%115654%13567 Jul. 1, 2009–Sep. 30, 20093%115654%13567 Oct. 1, 2009–Dec. 31, 20093%115654%13567 Jan. 1, 2010–Mar. 31, 20103%115654%13567 Apr. 1, 2010–Jun. 30, 20103%115654%13567 Jul. 1, 2010–Sep. 30, 20103%115654%13567 Oct. 1, 2010–Dec. 31, 20103%115654%13567 Jan. 1, 2011–Mar. 31, 20112%95633%11565 Apr. 1, 2011–Jun. 30, 20113%115654%13567 Jul. 1, 2011–Sep. 30, 20113%115654%13567 Oct. 1, 2011–Dec. 31, 20112%95633%11565 Jan. 1, 2012–Mar. 31, 20122%576113%59613 Apr. 1, 2012–Jun. 30, 20122%576113%59613 Jul. 1, 2012–Sep. 30, 20122%576113%59613 Oct. 1, 2012–Dec. 31, 20122%576113%59613 Jan. 1, 2013–Mar. 31, 20132%95633%11565 Apr. 1, 2013–Jun. 30, 20132%95633%11565 Jul. 1, 2013–Sep. 30, 20132%95633%11565 Oct. 1, 2013–Dec. 31, 20132%95633%11565 Jan. 1, 2014–Mar. 31, 20142%95633%11565 Apr. 1, 2014–Jun. 30, 20142%95633%11565 Jul. 1, 2014–Sep. 30, 20142%95633%11565 Oct. 1, 2014–Dec. 31, 20142%95633%11565 Jan. 1, 2015–Mar. 31, 20152%95633%11565 Apr. 1, 2015–Jun. 30, 20152%95633%11565 Jul. 1, 2015–Sep. 30, 20152%95633%11565 Oct. 1, 2015–Dec. 31, 20152%95633%11565 Jan. 1, 2016–Mar. 31, 20162%576113%59613 Apr. 1, 2016–Jun. 30, 20163%596134%61615 Jul. 1, 2016–Sep. 30, 20163%596134%61615 Oct. 1, 2016–Dec. 31, 20163%596134%61615 Jan. 1, 2017–Mar. 31, 20173%115654%13567 Apr. 1, 2017–Jun. 30, 20173%115654%13567 Jul. 1, 2017–Sep. 30, 20173%115654%13567 Oct. 1, 2017–Dec. 31, 20173%115654%13567 Jan. 1, 2018–Mar. 31, 20183%115654%13567 Apr. 1, 2018–Jun. 30, 20184%135675%15569 Jul. 1, 2018–Sep. 30, 20184%135675%15569 Oct. 1, 2018–Dec. 31, 20184%135675%15569 Jan. 1, 2019–Mar. 31, 20195%155696%17571 Apr. 1, 2019–Jun. 30, 20195%155696%17571 Jul. 1, 2019–Sep. 30, 20194%135675%15569 Oct. 1, 2019–Dec. 31, 20194%135675%15569 Jan. 1, 2020–Mar. 31, 20204%616155%63617 August 31, 2026 228 Bulletin No. 2026–36 Apr. 1, 2020–Jun. 30, 20204%616155%63617 Jul. 1, 2020–Sep. 30, 20202%576113%59613 Oct. 1, 2020–Dec. 31, 20202%576113%59613 Jan. 1, 2021–Mar. 31, 20212%95633%11565 Apr. 1, 2021–Jun. 30, 20212%95633%11565 Jul. 1, 2021–Sep. 30, 20212%95633%11565 Oct. 1, 2021–Dec. 31, 20212%95633%11565 Jan. 1, 2022–Mar. 31, 20222%95633%11565 Apr. 1, 2022–Jun. 30, 20223%115654%13567 Jul. 1, 2022–Sep. 30, 20224%135675%15569 Oct. 1, 2022–Dec. 31, 20225%155696%17571 Jan. 1, 2023–Mar. 31, 20236%175717%19573 Apr. 1, 2023–Jun. 30, 20236%175717%19573 Jul. 1, 2023–Sep. 30, 20236%175717%19573 Oct. 1, 2023–Dec. 31, 20237%195738%21575 Jan. 1, 2024–Mar. 31, 20247%676218%69623 Apr. 1, 2024–Jun. 30, 20247%676218%69623 Jul. 1, 2024–Sep. 30, 20247%676218%69623 Oct. 1, 2024–Dec. 31, 20247%676218%69623 Jan. 1, 2025–Mar. 31, 2025 6%175717%19573 Apr. 1, 2025–Jun. 30, 20256%175717%19573 Jul. 1, 2025–Sep. 30, 20256%175717%19573 Oct. 1, 2025–Dec. 31, 20256%175717%19573 Jan. 1, 2026–Mar. 31, 20266%175717%19573 Apr. 1, 2026–Jun. 30, 20265%155696%17571 Jul. 1, 2026–Sep. 30, 20266%175717%19573 Oct. 1, 2026–Dec. 31, 20266%175717%19573 Bulletin No. 2026–36 229 August 31, 2026 TABLE OF INTEREST RATES FOR LARGE CORPORATE UNDERPAYMENTS FROM JANUARY 1, 1991 – PRESENT 1995–1 C.B. PERIODRATETABLEPG Jan. 1, 1991–Mar. 31, 199113%31585 Apr. 1, 1991–Jun. 30, 199112%29583 Jul. 1, 1991–Sep. 30, 199112%29583 Oct. 1, 1991–Dec. 31, 199112%29583 Jan. 1, 1992–Mar. 31, 199211%75629 Apr. 1, 1992–Jun. 30, 199210%73627 Jul. 1, 1992–Sep. 30, 199210%73627 Oct. 1, 1992–Dec. 31, 19929%71625 Jan. 1, 1993–Mar. 31, 19939%23577 Apr. 1, 1993–Jun. 30, 19939%23577 Jul. 1, 1993–Sep. 30, 19939%23577 Oct. 1, 1993–Dec. 31, 19939%23577 Jan. 1, 1994–Mar. 31, 19949%23577 Apr. 1, 1994–Jun. 30, 19949%23577 Jul. 1, 1994–Sep. 30, 199410%25579 Oct. 1, 1994–Dec. 31, 199411%27581 Jan. 1, 1995–Jun. 30, 199511%27581 Apr. 1, 1995–Jun. 30, 199512%29583 Jul. 1, 1995–Sep. 30, 199511%27581 Oct. 1, 1995–Dec. 31, 199511%27581 Jan. 1, 1996–Mar. 31, 199611%75629 Apr. 1, 1996–Jun. 30, 199610%73627 Jul. 1, 1996–Sep. 30, 199611%75629 Oct. 1, 1996–Dec. 31, 199611%75629 Jan. 1, 1997–Mar. 31, 199711%27581 Apr. 1, 1997–Jun. 30, 199711%27581 Jul. 1, 1997–Sep. 30, 199711%27581 Oct. 1, 1997–Dec. 31, 199711%27581 Jan. 1, 1998–Mar. 31, 199811%27581 Apr. 1, 1998–Jun. 30, 199810%25579 Jul. 1, 1998–Sep. 30, 199810%25579 Oct. 1, 1998–Dec. 31, 199810%25579 Jan. 1, 1999–Mar. 31, 19999%23577 Apr. 1, 1999–Jun. 30, 199910%25579 Jul. 1, 1999–Sep. 30, 199910%25579 Oct. 1, 1999–Dec. 31, 199910%25579 Jan. 1, 2000–Mar. 31, 200010%73627 Apr. 1, 2000–Jun. 30, 200011%75629 Jul. 1, 2000–Sep. 30, 200011%75629 Oct. 1, 2000–Dec. 31, 200011%75629 Jan. 1, 2001–Mar. 31, 200111%27581 August 31, 2026 230 Bulletin No. 2026–36 Apr. 1, 2001–Jun. 30, 200110%25579 Jul. 1, 2001–Sep. 30, 20019%23577 Oct. 1, 2001–Dec. 31, 20019%23577 Jan. 1, 2002–Mar. 31, 20028%21575 Apr. 1, 2002–Sep. 30, 20028%21575 Jul. 1, 2002–Sep. 30, 20028%21575 Oct. 1, 2002–Dec. 31, 20028%21575 Jan. 1, 2003–Mar. 31, 20037%19573 Apr. 1, 2003–Jun. 30, 20037%19573 Jul. 1, 2003–Sep. 30, 20037%19573 Oct. 1, 2003–Dec. 31, 20036%17571 Jan. 1, 2004–Mar. 31, 20046%65619 Apr. 1, 2004–Jun. 30, 20047%67621 Jul. 1, 2004–Sep. 30, 20046%65619 Oct. 1, 2004–Dec. 31, 20047%67621 Jan. 1, 2005–Mar. 31, 20057%19573 Apr. 1, 2005–Jun. 30, 20058%21575 Jul. 1, 2005–Sep. 30, 20058%21575 Oct. 1, 2005–Dec. 31, 20059%23577 Jan. 1, 2006–Mar. 31, 20069%23577 Apr. 1, 2006–Jun. 30, 20069%23577 Jul. 1, 2006–Sep. 30, 200610%25579 Oct. 1, 2006–Dec. 31, 200610%25579 Jan. 1, 2007–Mar. 31, 200710%25579 Apr. 1, 2007–Jun. 30, 200710%25579 Jul. 1, 2007–Sep. 30, 200710%25579 Oct. 1, 2007–Dec. 31, 200710%25579 Jan. 1, 2008–Mar. 31, 20089%71625 Apr. 1, 2008–Sep. 30, 20088%69623 Jul. 1, 2008–Sep. 30, 20087%67621 Oct. 1, 2008–Dec. 31, 20088%69623 Jan. 1, 2009–Mar. 31, 20097%19573 Apr. 1, 2009–Jun. 30, 20096%17571 Jul. 1, 2009–Sep. 30, 20096%17571 Oct. 1, 2009–Dec. 31, 20096%17571 Jan. 1, 2010–Mar. 31, 20106%17571 Apr. 1, 2010–Jun. 30, 20106%17571 Jul. 1, 2010–Sep. 30, 20106%17571 Oct. 1, 2010–Dec. 31, 20106%17571 Jan. 1, 2011–Mar. 31, 20115%15569 Apr. 1, 2011–Jun. 30, 20116%17571 Jul. 1, 2011–Sep. 30, 20116%17571 Oct. 1, 2011–Dec. 31, 20115%15569 Jan. 1, 2012–Mar. 31, 20125%63617 Apr. 1, 2012–Jun. 30, 20125%63617 Bulletin No. 2026–36 231 August 31, 2026 Jul. 1, 2012–Sep. 30, 20125%63617 Oct. 1, 2012–Dec. 31, 20125%63617 Jan. 1, 2013–Mar. 31, 20135%15569 Apr. 1, 2013–Jun. 30, 20135%15569 Jul. 1, 2013–Sep. 30, 20135%15569 Oct. 1, 2013–Dec. 31, 20135%15569 Jan. 1, 2014–Mar. 31, 20145%15569 Apr. 1, 2014–Jun. 30, 20145%15569 Jul. 1, 2014–Sep. 30, 20145%15569 Oct. 1, 2014–Dec. 31, 20145%15569 Jan. 1, 2015–Mar. 31, 20155%15569 Apr. 1, 2015–Jun. 30, 20155%15569 Jul. 1, 2015–Sep. 30, 20155%15569 Oct. 1, 2015–Dec. 31, 20155%15569 Jan. 1, 2016–Mar. 31, 20165%63617 Apr. 1, 2016–Jun. 30, 20166%65619 Jul. 1, 2016–Sep. 30, 20166%65619 Oct. 1, 2016–Dec. 31, 20166%65619 Jan. 1, 2017–Mar. 31, 20176%17571 Apr. 1, 2017–Jun. 30, 20176%17571 Jul. 1, 2017–Sep. 30, 20176%17571 Oct. 1, 2017–Dec. 31, 20176%17571 Jan. 1, 2018–Mar. 31, 20186%17571 Apr. 1, 2018–Jun. 30, 20187%19573 Jul. 1, 2018–Sep. 30, 20187%19573 Oct. 1, 2018–Dec. 31, 20187%19573 Jan. 1, 2019–Mar. 31, 20198%21575 Apr. 1, 2019–Jun. 30, 20198%21575 Jul. 1, 2019–Sep. 30, 20197%19573 Oct. 1, 2019–Dec. 31, 20197%19573 Jan. 1, 2020–Mar. 31, 20207%67621 Apr. 1, 2020–Jun. 30, 20207%67621 Jul. 1, 2020–Sep. 30, 20205%63617 Oct. 1, 2020–Dec. 31, 20205%63617 Jan. 1, 2021–Mar. 31, 20215%15569 Apr. 1, 2021–Jun. 30, 20215%15569 Jul. 1, 2021–Sep. 30, 20215%15569 Oct. 1, 2021–Dec. 31, 20215%15569 Jan. 1, 2022–Mar. 31, 20225%15569 Apr. 1, 2022–Jun. 30, 20226%17571 Jul. 1, 2022–Sep. 30, 20227%19573 Oct. 1, 2022–Dec. 31, 20228%21575 Jan. 1, 2023–Mar. 31, 20239%23577 Apr. 1, 2023–Jun. 30, 20239%23577 Jul. 1, 2023–Sep. 30, 20239%23577 August 31, 2026 232 Bulletin No. 2026–36 Oct. 1, 2023–Dec. 31, 202310%25579 Jan. 1, 2024–Mar. 31, 202410%73627 Apr. 1, 2024–Jun. 30, 202410%73627 Jul. 1, 2024–Sep. 30, 202410%73627 Oct. 1, 2024–Dec. 31, 202410%73627 Jan. 1, 2025–Mar. 31, 20259%23577 Apr. 1, 2025–Jun. 30, 20259%23577 Jul. 1, 2025–Sep. 30, 20259%23577 Oct. 1, 2025–Dec. 31, 20259%23577 Jan. 1, 2026–Mar. 31, 20269%23577 Apr. 1, 2026–Jun. 30, 20268%21575 Jul. 1, 2026–Sep. 30, 20269%23577 Oct. 1, 2026–Dec. 31, 20269%23577 Bulletin No. 2026–36 233 August 31, 2026 TABLE OF INTEREST RATES FOR CORPORATE OVERPAYMENTS EXCEEDING $10,000 FROM JANUARY 1, 1995 – PRESENT 1995–1 C.B. PERIODRATETABLEPG Jan. 1, 1995–Mar. 31, 19956.5%18572 Apr. 1, 1995–Jun. 30, 19957.5%20574 Jul. 1, 1995–Sep. 30, 19956.5%18572 Oct. 1, 1995–Dec. 31, 19956.5%18572 Jan. 1, 1996–Mar. 31, 19966.5%66620 Apr. 1, 1996–Jun. 30, 19965.5%64618 Jul. 1, 1996–Sep. 30, 19966.5%66620 Oct. 1, 1996–Dec. 31, 19966.5%66620 Jan. 1, 1997–Mar. 31, 19976.5%18572 Apr. 1, 1997–Jun. 30, 19976.5%18572 Jul. 1, 1997–Sep. 30, 19976.5%18572 Oct. 1, 1997–Dec. 31, 19976.5%18572 Jan. 1, 1998–Mar. 31, 19986.5%18572 Apr. 1, 1998–Jun. 30, 19985.5%16570 Jul. 1, 1998–Sep. 30, 19985.5%16570 Oct. 1, 1998–Dec. 31, 19985.5%16570 Jan. 1, 1999–Mar. 31, 19994.5%14568 Apr. 1, 1999–Sep. 30, 19995.5%16570 Jul. 1, 1999–Sep. 30, 19995.5%16570 Oct. 1, 1999–Dec. 31, 19995.5%16570 Jan. 1, 2000–Mar. 31, 20005.5%64618 Apr. 1, 2000–Jun. 30, 20006.5%66620 Jul. 1, 2000–Sep. 30, 20006.5%66620 Oct. 1, 2000–Dec. 31, 20006.5%66620 Jan. 1, 2001–Mar. 31, 20016.5%18572 Apr. 1, 2001–Jun. 30, 20015.5%16570 Jul. 1, 2001–Sep. 30, 20014.5%14568 Oct. 1, 2001–Dec. 31, 20014.5%14568 Jan. 1, 2002–Mar. 31, 20023.5%12566 Apr. 1, 2002–Jun. 30, 20023.5%12566 Jul. 1, 2002–Sep. 30, 20023.5%12566 Oct. 1, 2002–Dec. 31, 20023.5%12566 Jan. 1, 2003–Mar. 31, 20032.5%10564 Apr. 1, 2003–Jun. 30, 20032.5%10564 Jul. 1, 2003–Sep. 30, 20032.5%10564 Oct. 1, 2003–Dec. 31, 20031.5%8562 Jan. 1, 2004–Mar. 31, 20041.5%56610 Apr. 1, 2004–Jun. 30, 20042.5%58612 August 31, 2026 234 Bulletin No. 2026–36 Jul. 1, 2004–Sep. 30, 20041.5%56610 Oct. 1, 2004–Dec. 31, 20042.5%58612 Jan. 1, 2005–Mar. 31, 20052.5%10564 Apr. 1, 2005–Jun. 30, 20053.5%12566 Jul. 1, 2005–Sep. 30, 20053.5%12566 Oct. 1, 2005–Dec. 31, 20054.5%14568 Jan. 1, 2006–Mar. 31, 20064.5%14568 Apr. 1, 2006–Jun. 30, 20064.5%14568 Jul. 1, 2006–Sep. 30, 20065.5%16570 Oct. 1, 2006–Dec. 31, 20065.5%16570 Jan. 1, 2007–Mar. 31, 20075.5%16570 Apr. 1, 2007–Jun. 30, 20075.5%16570 Jul. 1, 2007–Sep. 30, 20075.5%16570 Oct. 1, 2007–Dec. 31, 20075.5%16570 Jan. 1, 2008–Mar. 31, 20084.5%62616 Apr. 1, 2008–Jun. 30, 20083.5%60614 Jul. 1, 2008–Sep. 30, 20082.5%58612 Oct. 1, 2008–Dec. 31, 20083.5%60614 Jan. 1, 2009–Mar. 31, 20092.5%10564 Apr. 1, 2009–Jun. 30, 20091.5%8562 Jul. 1, 2009–Sep. 30, 20091.5%8562 Oct. 1, 2009–Dec. 31, 20091.5%8562 Jan. 1, 2010–Mar. 31, 20101.5%8562 Apr. 1, 2010–Jun. 30, 20101.5%8562 Jul. 1, 2010–Sep. 30, 20101.5%8562 Oct. 1, 2010–Dec. 31, 20101.5%8562 Jan. 1, 2011–Mar. 31, 20110.5%* Apr. 1, 2011–Jun. 30, 20111.5%8562 Jul. 1, 2011–Sep. 30, 20111.5%8562 Oct. 1, 2011–Dec. 31, 20110.5%* Jan. 1, 2012–Mar. 31, 20120.5%* Apr. 1, 2012–Jun. 30, 20120.5%* Jul. 1, 2012–Sep. 30, 20120.5%* Oct. 1, 2012–Dec. 31, 20120.5%* Jan. 1, 2013–Mar. 31, 20130.5%* Apr. 1, 2013–Jun. 30, 20130.5%* Jul. 1, 2013–Sep. 30, 20130.5%* Oct. 1, 2013–Dec. 31, 20130.5%* Jan. 1, 2014–Mar. 31, 20140.5%* Apr. 1, 2014–Jun. 30, 20140.5%* Jul. 1, 2014–Sep. 30, 20140.5%* Oct. 1, 2014–Dec. 31, 20140.5%* Bulletin No. 2026–36 235 August 31, 2026 Jan. 1, 2015–Mar. 31, 20150.5%* Apr. 1, 2015–Jun. 30, 20150.5%* Jul. 1, 2015–Sep. 30, 20150.5%* Oct. 1, 2015–Dec. 31, 20150.5%* Jan. 1, 2016–Mar. 31, 20160.5%* Apr. 1, 2016–Jun. 30, 20161.5%56610 Jul. 1, 2016–Sep. 30, 20161.5%56610 Oct. 1, 2016–Dec. 31, 20161.5%56610 Jan. 1, 2017–Mar. 31, 20171.5%8562 Apr. 1, 2017–Jun. 30, 20171.5%8562 Jul. 1, 2017–Sep. 30, 20171.5%8562 Oct. 1, 2017–Dec. 31, 20171.5%8562 Jan. 1, 2018–Mar. 31, 20181.5%8562 Apr. 1, 2018–Jun. 30, 20182.5%10564 Jul. 1, 2018–Sep. 30, 20182.5%10564 Oct. 1, 2018–Dec. 31, 20182.5%10564 Jan. 1, 2019–Mar. 31, 20193.5%12566 Apr. 1, 2019–Jun. 30, 20193.5%12566 Jul. 1, 2019–Sep. 30, 20192.5%10564 Oct. 1, 2019–Dec. 31, 20192.5%10564 Jan. 1, 2020–Mar. 31, 20202.5%58612 Apr. 1, 2020–Jun. 30, 20202.5%58612 Jul. 1, 2020–Sep. 30, 20200.5%* Oct. 1, 2020–Dec. 31, 20200.5%* Jan. 1, 2021–Mar. 31, 20210.5%* Apr. 1, 2021–Jun. 30, 20210.5%* Jul. 1, 2021–Sep. 30, 20210.5%* Oct. 1, 2021–Dec. 31, 20210.5%* Jan. 1, 2022–Mar. 31, 20220.5%* Apr. 1, 2022–Jun. 30, 20221.5%8562 Jul. 1, 2022–Sep. 30, 20222.5%10564 Oct. 1, 2022–Dec. 31, 20223.5%12566 Jan. 1, 2023–Mar. 31, 20234.5%14568 Apr. 1, 2023–Jun. 30, 20234.5%14568 Jul. 1, 2023–Sep. 30, 2023 4.5%14568 Oct. 1, 2023–Dec. 31, 20235.5%16570 Jan. 1, 2024–Mar. 31, 2024 5.5%64618 Apr. 1, 2024–Jun. 30, 20245.5%64618 Jul. 1, 2024–Sep. 30, 20245.5%64618 Oct. 1, 2024–Dec. 31, 20245.5%64618 Jan. 1, 2025–Mar. 31, 20254.5%14568 Apr. 1, 2025–Jun. 30, 20254.5%14568 August 31, 2026 236 Bulletin No. 2026–36 Jul. 1, 2025–Sep. 30, 20254.5%14568 Oct. 1, 2025–Dec. 31, 20254.5%14568 Jan. 1, 2026–Mar. 31, 20264.5%14568 Apr. 1, 2026–Jun. 30, 20263.5%12566 Jul. 1, 2026–Sep. 30, 20264.5%14568 Oct. 1, 2026–Dec. 31, 20264.5% 14568 * The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of this Revenue Ruling. Bulletin No. 2026–36 237 August 31, 2026 Section 1256.—Section 1256 Contracts Marked to Market (Also §§ 446, 481, 7805; 1.446-1, 301.7805-1). Rev. Rul. 2026-16 ISSUE Is ICE Endex, which is a regulated exchange of the Netherlands, a qualified board or exchange within the meaning of § 1256(g)(7)(C) of the Internal Revenue Code (Code) 1 ? FACTS ICE Endex is a regulated exchange of the Netherlands. On December 23, 2011, the Commod- ity Futures Trading Commission (CFTC) published final rules regarding the regis- tration with the CFTC of foreign boards of trade (FBOT). See Registration of For- eign Boards of Trade, 76 FR 80674 (Dec. 23, 2011), codified at 17 CFR Part 48, and as amended by 89 FR 66201 (Aug. 15, 2024). The effective date for the final rules generally was February 21, 2012. Under the CFTC FBOT registration system, the CFTC may issue an Order of Registration to an FBOT, allowing the FBOT to pro- vide direct access to its electronic trad- ing and order matching system from the United States. On January 10, 2017, the CFTC granted an Order of Registration to ICE Endex under the CFTC FBOT registra- tion system. An FBOT’s status under the CFTC FBOT registration system is posted online by the CFTC. L AW Section 1256(g)(7) provides that the term “qualified board or exchange” means: (A) a national securities exchange that is registered with the Securities and Exchange Commission, (B) a domestic board of trade designated as a contract market by the CFTC, or (C) any other exchange, board of trade, or other market that the Secretary of the Treasury or the Secretary’s delegate deter- mines has rules adequate to carry out the purposes of § 1256. HOLDING The Internal Revenue Service deter- mines that ICE Endex, which is a reg- ulated exchange of the Netherlands, is a qualified board or exchange within the meaning of § 1256(g)(7)(C) as long as ICE Endex holds a valid Order of Regis- tration under the CFTC FBOT registration system. PROSPECTIVE APPLICATION Under the authority of § 7805(b)(8), this revenue ruling is effective for ICE Endex Contracts entered into on or after Septem- ber 1, 2026. For purposes of this revenue ruling, the term “ICE Endex Contracts” means futures contracts and futures con- tract options that are traded on or subject to the rules of ICE Endex, that are described in § 1256(g)(1)(A), and that are not cov- ered by the exception in § 1256(b)(2). CHANGE IN METHOD OF ACCOUNTING A change in the treatment of ICE Endex Contracts to reflect the determination made in this revenue ruling is a change in method of accounting within the mean- ing of §§ 446 and 481 and the regulations thereunder. The Commissioner of Internal Revenue grants consent to a taxpayer to change its method of accounting for ICE Endex Contracts entered into on or after September 1, 2026, to the § 1256 mark- to-market method for the first taxable year during which the taxpayer holds such contracts. The requirement to file a Form 3115, Application for Change in Accounting Method, in § 1.446-1(e)(3)(i) is waived. The change is made on a cut-off basis and is inapplicable to ICE Endex Contracts that were entered into before September 1, 2026. Because the change is made on a “cut-off” basis, there is no potential omission or duplication of income or deductions, and an adjust- ment under § 481 is neither permitted nor required. DRAFTING INFORMATION The principal author of this revenue ruling is Shawn Tetelman of the Office of Associate Chief Counsel (Financial Insti- tutions & Products). For further informa- tion regarding this revenue ruling, contact Shawn Tetelman at (202) 317-7053 (not a toll-free number). 26 CFR 31.3406(a)-1; 26 CFR 31.3406(b)(3)-5 TD 10053 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 31 Backup Withholding on Third Party Network Transactions AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains final regulations governing backup with- holding on reportable payments with respect to third party network transac- tions. The final regulations reflect recent changes to the statutory law that affect the backup withholding requirements for third party settlement organizations who make payments in settlement of third party net- work transactions. DATES: Effective date: These regulations are effective on August 10, 2026. Applicability dates: For dates of applicability, see §§ 31.3406(a)-1(e) and 31.3406(b)(3)-5(e). 1 Unless otherwise specified, all “Section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR Part 1). August 31, 2026 238 Bulletin No. 2026–36 FOR FURTHER INFORMATION CONTACT: Casey Conrad, Office of Associate Chief Counsel (Procedure and Administration) at (202) 317-6844 (not a toll-free number). SUPPLEMENTARY INFORMATION: Authority This document contains amendments to the Regulations on Employment Taxes and Collection of Income Tax at the Source (26 CFR part 31) under sec- tion 3406 of the Internal Revenue Code (Code). The final regulations are issued under the authority conferred by section 3406(i) of the Code, which provides the Secretary of the Treasury or the Secre- tary’s delegate (Secretary) with authority to “prescribe such regulations as may be necessary or appropriate to carry out the purposes of [section 3406].” The final regulations are also issued pursuant to section 7805(a) of the Code, which authorizes the Secretary to “pre- scribe all needful rules and regulations for the enforcement of [the Code], including all rules and regulations as may be neces- sary by reason of any alteration of law in relation to internal revenue.” Background This document contains amendments to regulations under 26 CFR part 31. On January 9, 2026, the Department of the Treasury (Treasury Department) and the IRS published in the Federal Reg- ister (91 FR 934) a notice of proposed rulemaking (REG-112829-25) proposing amendments to the regulations govern- ing backup withholding on third party network transactions under section 3406 (proposed regulations) to reflect the stat- utory changes made to section 3406(b) by section 70432 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). No public hearing was requested or held with respect to the pro- posed regulations. The Treasury Department and the IRS received eight comments in response to the proposed regulations. After consideration of these comments, the proposed regula- tions are adopted without change. To the extent not inconsistent with the Summary of Comments section of this preamble, the Explanation of Provisions section of the preamble to the proposed regulations is incorporated in this document. Summary of Comments One commenter suggested that the changes to the final regulations take place prospectively only. The final regu- lations do not adopt this comment. The changes to section 3406 made by section 70432(b)(1) of the OBBBA apply to cal- endar years beginning after December 31, 2024. These final regulations remove provisions from the existing regula- tions that conflict with section 3406, as amended by the OBBBA, and implement the changes to section 3406 made by the OBBBA. Thus, to prevent taxpayer con- fusion that might arise from a conflict between the statutory text of section 3406 and the text of the regulations, and to adhere to the effective date prescribed in the OBBBA by Congress for the changes made to section 3406, the applicability date for these final regulations mirrors the effective date of section 70432(b) (1) of the OBBBA (that is, the final reg- ulations apply with respect to payments made in calendar years beginning after December 31, 2024), consistent with the proposed regulations. One commenter expressed general sup- port for the proposed regulations but rec- ommended that the Treasury Department and the IRS include additional information in the preamble to this Treasury decision. The commenter recommended the Trea- sury Department and the IRS add a com- pliance-and-enforcement-implications section to this preamble to reduce tax con- troversy disputes and clarify that: (1) the taxability of income is not affected by the absence of a Form 1099-K, Payment Card and Third Party Network Transactions, or the absence of backup withholding on payments made in settlement of third party network transactions; (2) the new de minimis threshold for backup withholding does not create a safe harbor for structur- ing, account-splitting, or other conduct intended to avoid information reporting or backup withholding; and (3) that the IRS may use enforcement tools during an examination to confirm the amount of a taxpayer’s income regardless of whether a taxpayer exceeds the de minimis third party settlement organization (TPSO) reporting or backup withholding thresh- old. Although these recommendations are outside of the scope of these regulations, the Treasury Department and the IRS agree that it is important to emphasize that the taxability of payments and the reportability of income on an income tax return are not determined by whether the IRS or the taxpayer receives a Form 1099- K, or by whether backup withholding is required with respect to a third party net- work transaction. This commenter also recommended that the Treasury Department and the IRS clarify that TPSOs are responsible for internally aggregating multiple accounts with identical identifying information indicating common beneficial ownership or the same taxpayer identification num- ber. Although this comment is also outside of the scope of these regulations, the Trea- sury Department and the IRS agree that it is helpful to clarify that the de minimis TPSO reporting and backup withhold- ing thresholds referenced throughout this Treasury decision apply with respect to each participating payee, as defined by section 6050W(d)(1). Three commenters expressed concerns that the proposed regulations were confus- ing or could be drafted more clearly, but none suggested any alternative language or clarifying edits. The final regulations do not make any changes with respect to these comments, as the final regulations merely implement statutory changes in response to changes made by section 70432(b)(1) of the OBBBA. One commenter submitted three sep- arate comments and attached documents. In one comment, the commenter requested that the IRS transmit the commenter’s comment and all related materials to the Office of Management and Budget (OMB), the Office of Information and Regulatory Affairs (OIRA), the Govern- ment Accountability Office (GAO), and the Department of the Treasury Office of Inspector General for independent review under the Paperwork Reduction Act, the Administrative Procedure Act, the Regu- latory Flexibility Act, and various Execu- tive Orders governing regulatory review, Bulletin No. 2026–36 239 August 31, 2026 economic impact, and burden reduction. The commenter suggested that the Trea- sury Department and the IRS failed to comply with relevant administrative requirements in promulgating the pro- posed regulations, or at the least under- stated the expected burden and economic impact on taxpayers. The Treasury Department and the IRS complied with all relevant administrative laws, including the Paperwork Reduc- tion Act, the Administrative Procedure Act, the Regulatory Flexibility Act, and applicable Executive Orders in the prom- ulgation of the proposed regulations and these final regulations. The description of the Treasury Department and the IRS’s compliance with these administrative requirements can be found in the Special Analyses section of the proposed regula- tions and the Special Analyses section in this Treasury decision. The commenter also submitted thirty attachments that consisted of requests and demands, the substantial majority of which were outside of the scope of the proposed regulations. For example, the commenter requested that the Treasury Department and the IRS coordinate with the Com- modity Futures Trading Commission (CFTC) to issue joint guidance clarifying that CFTC commodity classification gov- erns the section 3406 backup withholding treatment of digital commodity settlement payments. The commenter also requested that the Treasury Department and the IRS exempt certain types of payments from all backup withholding, including patent royalty payments, dividend payments, and payments for defense-related goods and services to defense technology compa- nies registered under International Traffic in Arms Regulations (22 CFR parts 120 through 130). No changes were made based on these comments because these final regulations are limited to backup withholding on third party network trans- actions, not any broader issues related to backup withholding. The remaining comments were tangen- tially related to the subject matter of the proposed regulations on their face but are nonetheless outside of the scope of these regulations. For example, one commenter requested that the Treasury Department and the IRS analyze the impact of adopt- ing different section 6050W de minimis TPSO reporting thresholds and adopt the commenter’s desired threshold of $200,000 in payments and 10,000 trans- actions. The Treasury Department and the IRS lack the authority to change the statu- torily prescribed amount of the de mini- mis TPSO reporting threshold in these final regulations. Instead, the final regula- tions implement the statutory requirement under section 3406, as amended by sec- tion 70432(b)(1) of the OBBBA, to align the backup withholding threshold for third party network transactions with the de minimis TPSO reporting threshold under section 6050W. To the extent a comment, or portion of a comment, was not discussed in this preamble, the Treasury Department and the IRS determined that the comment, or portion of the comment, pertained to top- ics outside of the scope of these final reg- ulations. 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 Memorandum of Agreement (July 4, 2025) between the Treasury Department and OMB regarding review of tax regulations. II. Regulatory Flexibility Act Pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby cer- tified that these final regulations will not have a significant economic impact on a substantial number of small entities. The final regulations affect any entity required to file information returns reporting pay- ments of third party network transactions. The final regulations could affect a sub- stantial number of small entities; however, the economic impact of the final regula- tions is not likely to be significant because the final regulations do not impose any new requirements on small entities. Rather, the final regulations clarify the threshold at which entities are required to backup withhold for reportable payments where certain conditions are met. Because the threshold to backup withhold on third party network transaction payments increases under the final regulations, the final regulations would reduce the fre- quency with which entities must backup withhold. Thus, the economic impact of these final regulations is not likely to be significant. III. 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 collection of information in these final regulations relates to recordkeeping and information reporting with respect to backup withholding in §31.3406(b)(3)-5. The collected information will be used by the payor to determine whether payments to the payee exceed a threshold that would require backup withholding and the issu- ance 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 con- trol number 1545-0029 and the associated burden is included in the estimates shown in the Instructions for Form 941. The Form 941 and its instructions were updated in March 2026, and any decrease in burden associated with the statutory changes to section 3406 is reflected in those instruc- tions because the burden estimates were based on statutory requirements in effect as of October 1, 2025, which includes the amendments made by section 70432(b)(1) of the OBBBA. IV. Submission to Small Business Administration Pursuant to section 7805(f) of the Code, the proposed regulations preceding these final regulations were submitted to the Chief Counsel for the Office of Advo- cacy of the Small Business Administration for comment on its impact on small busi- ness. No comments were received. August 31, 2026 240 Bulletin No. 2026–36 V. Unfunded Mandates Reform Act Section 202 of the Unfunded Mandates Reform Act of 1995 requires that agencies assess anticipated costs and benefits and take certain other actions before issuing a final rule that includes any Federal man- date that may result in expenditures in any one year by a State, local, or Tribal government, in the aggregate, or by the private sector, of $100 million in 1995 dollars, updated annually for inflation. These final regulations do not include any Federal mandate that may result in 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 Executive Order. These final regulations do not have federalism implications, do not impose substantial direct compliance costs on State and local governments, and do not preempt State law within the meaning of the Executive Order. 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). Statement of Availability of IRS Documents IRS Revenue Rulings, Revenue Proce- dures, Notices, and other guidance cited in this document are published in the Inter- nal Revenue Bulletin (or Cumulative Bul- letin) and are available from the Superin- tendent of Documents, U.S. Government Printing Office, Washington, DC 20402, or by visiting the IRS website at https:// www.irs.gov. Drafting Information The principal author of these final reg- ulations is the Office of Associate Chief Counsel (Procedure and Administration). However, other personnel from the Trea- sury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 31 Employment taxes, Income taxes, Penalties, Pensions, Railroad retirement, Reporting and recordkeeping require- ments, Social security, Unemployment compensation. Amendments to the Regulations Accordingly, the Treasury Department and the IRS amend 26 CFR part 31 as fol- lows: PART 31–EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE Paragraph 1. The authority citation for part 31 continues to read in part as fol- lows: Authority: 26 U.S.C. 7805. * * * * * Par. 2. Section 31.3406(a)-1 is amended by revising paragraphs (a) and (c), and adding paragraph (e) to read as follows: §31.3406(a)-1 Backup withholding requirement on reportable payments. (a) Overview. Under section 3406 of the Internal Revenue Code (Code), a payor must deduct and withhold an amount equal to the product of the fourth lowest rate of tax applicable under section 1(c) of the Code and a reportable payment if a condition for withholding exists. Report- able payments mean interest and dividend payments (as defined in section 3406(b) (2)) and other reportable payments (as defined in section 3406(b)(3)). The condi- tions described in paragraph (b)(1) of this section apply to all reportable payments, including reportable interest and dividend payments. The conditions described in paragraph (b)(2) of this section apply only to reportable interest and dividend pay- ments. * * * * * (c) Exceptions. The requirement to withhold does not apply to certain de minimis payments as described in §§31.3406(b)(3)-1(b)(3), 31.3406(b)(3)- 5(b)(2), and 31.3406(b)(4)-1 or to pay- ments exempt from withholding under §§31.3406(g)-1 through 31.3406(g)-3. * * * * * (e) Applicability date. The provisions of this section apply with respect to pay- ments made in calendar years beginning after December 31, 2024. Par. 3. Section 31.3406(b)(3)-5 is amended by revising paragraphs (b) and (e) to read as follows: §31.3406(b)(3)-5 Reportable payments of payment card and third party network transactions. * * * * * (b) Amount subject to backup withhold- ing–(1) In general. The amount described in paragraph (a) of this section that is sub- ject to withholding under section 3406 is the amount subject to reporting under sec- tion 6050W. (2) Third party network transactions. In the case of payments made in settle- ment of third party network transactions, the amount subject to withholding under section 3406 is determined with regard to the exception for de minimis payments by third party settlement organizations in section 6050W(e). A payment is treated as a reportable payment under paragraph (a) of this section only if, during the calen- dar year, the aggregate number of trans- actions with respect to the participating payee exceeds the number of transactions specified in section 6050W(e)(2) and the aggregate amount of all reportable pay- ment transactions with respect to such participating payee exceeds the dollar amount specified in section 6050W(e) (1). The amount subject to withholding is the entire amount of the transaction that causes either the total number of trans- actions to exceed the number of transac- tions specified in section 6050W(e)(2), or the entire amount of the transaction that causes the total amount paid to the partic- ipating payee to exceed the dollar amount Bulletin No. 2026–36 241 August 31, 2026 specified in section 6050W(e)(1) at the time of such payment, whichever occurs later, and the amount of any subsequent transactions made to the participating payee during the calendar year. (3) Exception. Paragraph (b)(2) of this section does not apply with respect to pay- ments to any participating payee during any calendar year if one or more payments in settlement of third party network trans- actions made by the payor to the partici- pating payee during the preceding calen- dar year were reportable payments. (4) Examples. The provisions of this paragraph (b) are illustrated by the follow- ing examples: (i) Example 1. Platform A is a third party settle- ment organization (as defined in §1.6050W-1(c)(2) of this chapter) and Y is a participating payee (as defined in §1.6050W-1(a)(5)(i)(B) of this chapter). A complies with all the requirements to solicit a taxpayer identification number (TIN) from Y, but Y does not provide its TIN to A. During calendar year 2026, A makes 201 payments in settlement of third party network transactions that total $20,000.01. A must backup withhold under paragraph (b)(2) of this section on the entire amount of the 201st transaction because that transaction caused Y to exceed the de minimis reporting threshold for calendar year 2026 of 200 transactions and $20,000 in gross payments. (ii) Example 2. The facts are the same as in para- graph (b)(4)(i) of this section (Example 1). During calendar year 2027, A makes 199 payments in set- tlement of third party network transactions that total $18,000.00. A must backup withhold on each pay- ment made to Y in settlement of a third party net- work transaction during 2027 under paragraph (b) (3) of this section because one or more payments in settlement of third party network transactions made by A to Y during the preceding calendar year (2026) were reportable payments. (iii) Example 3. The facts are the same as in para- graph (b)(4)(ii) of this section (Example 2). During calendar year 2028, A makes four payments in set- tlement of third party network transactions that total $2,000.00. A must backup withhold on each payment made in settlement of a third party network trans- action during 2028 under paragraph (b)(3) of this section because one or more payments in settlement of third party network transactions made by A to Y during the preceding calendar year (2027) were reportable payments. (iv) Example 4. The facts are the same as in para- graph (b)(4)(iii) of this section (Example 3). During calendar year 2029, A made no payments in settle- ment of third party network transactions, and during calendar year 2030, A makes 199 payments in set- tlement of third party network transactions that total $18,000.00. A is not required to backup withhold on any payment made in settlement of third party net- work transactions during calendar year 2030 because A did not make any reportable payments to Y during the preceding calendar year (2029), and A did not make payments in settlement of third party network transactions that exceed the de minimis reporting threshold. * * * * * (e) Applicability date. The provisions of this section apply with respect to pay- ments made in calendar years beginning after December 31, 2024. Frank J. Bisignano, Chief Executive Officer. Approved: July 23, 2026. Kenneth J. Kies. Assistant Secretary of the Treasury (Tax Policy). (Filed by the Office of the Federal Register August 7, 2026, 8:45 a.m., and published in the issue of the Federal Register for August 10, 2026, 91 FR 51391) August 31, 2026 242 Bulletin No. 2026–36 Part III Safe Harbor for the Credit for Carbon Oxide Sequestration under Section 45Q for Qualified Carbon Oxide Reported under Subpart RR Notice 2026-50 SECTION 1. PURPOSE Notice 2026-1, 2026-4 I.R.B. 365, provides interim guidance, pending the issuance of forthcoming proposed regu- lations, relating to the credit for carbon oxide sequestration under § 45Q (§ 45Q credit) of the Internal Revenue Code (Code) 1 in light of the Environmental Protection Agency’s (EPA) proposed reg- ulations to remove reporting obligations regarding the geological sequestration of carbon dioxide imposed under subpart RR of 40 CFR part 98 (subpart RR) of the Greenhouse Gas Reporting Program (GHGRP). See 90 F.R. 44591 (Sept. 16, 2025). This notice modifies and amplifies Notice 2026-1 by expanding the scope of the safe harbor provided in Notice 2026-1 to include qualified carbon oxide that is used as a tertiary injectant in a qualified enhanced oil or natural gas recovery proj- ect and the determination of the amount of qualified carbon oxide subject to recap- ture. This notice also extends the applica- bility date of the safe harbor provided in Notice 2026-1. SECTION 2. BACKGROUND Notice 2026-1 provided a safe harbor for determining eligibility for the § 45Q credit for qualified carbon oxide that is captured and disposed of in secure geo- logical storage and not used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project, but did not address eligibility for qualified carbon oxide that is used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project because there were other available reporting standards that could be used to claim the § 45Q credit for 2025. Stakeholders have explained, however, that taxpayers claiming the § 45Q credit for a qualified enhanced oil or natural gas recovery project are potentially unable to transition from the subpart RR standard to other available reporting standards in time to claim the § 45Q credit for 2025, or would incur significant costs, timeline constraints, and compliance issues in trying to do so. Other stakeholders have explained that the limited applicability of the safe harbor to the storage of qualified carbon oxide that occurs in calendar year 2025 is creating uncertainty for projects with long investment horizons. Finally, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have received inquiries as to whether tax- payers claiming the § 45Q credit may rely upon the safe harbor provided in Notice 2026-1 to determine the amount of qual- ified carbon oxide securely stored in geo- logical storage and the amount of qualified carbon oxide leaked into the atmosphere for purposes of determining the amount of qualified carbon oxide subject to recapture under § 1.45Q-5(a) and (c). In view of the unique circumstances resulting from the proposed removal of subpart RR of the GHGRP, and in consul- tation with the Administrator of the EPA, the Secretary of Energy, and the Secretary of the Interior, the Treasury Department and the IRS are extending and expanding the safe harbor provided in Notice 2026-1 in the manner specified in this notice. SECTION 3. MODIFICATIONS TO NOTICE 2026-1 .01 Modification of Section 2 of Notice 2026-1. This section 3.01 modifies and amplifies section 2 of Notice 2026-1 by revising section 2.01(8), adding new section 2.01(11) and (12), revising sec- tion 2.02(1) and (2), adding new section 2.02(5), and making several nonsubstan- tive modifications in other sections. As so modified and amplified, section 2 of Notice 2026-1 now reads: SECTION 2. BACKGROUND .01 Section 45Q. (1) Section 45Q was added to the Code by § 115 of Division B of the Energy Improvement and Extension Act of 2008, Pub. L. 110-343, 122 Stat. 3765, 3829 (Oct. 3, 2008). Section 45Q was amended a number of times thereafter, including most recently by § 70522 of Public Law 119-21, 139 Stat. 72, 279 (July 4, 2025), commonly known as the One, Big, Beau- tiful Bill Act (OBBBA). 2 (2) Section 45Q(a)(1) allows a credit of $20 per metric ton of qualified carbon oxide (i) captured by the taxpayer using carbon capture equipment which is origi- nally placed in service at a qualified facil- ity before February 9, 2018; (ii) disposed of by the taxpayer in secure geological storage; and (iii) neither used by the tax- payer as a tertiary injectant in a qualified enhanced oil or natural gas recovery proj- ect nor utilized in a manner described in § 45Q(f)(5). (3) Section 45Q(a)(2) allows a credit of $10 per metric ton of qualified carbon oxide (i) captured by the taxpayer using carbon capture equipment which is origi- nally placed in service at a qualified facil- ity before February 9, 2018; and (ii) either (A) used by the taxpayer as a tertiary injectant in a qualified enhanced oil or nat- ural gas recovery project and disposed of by the taxpayer in secure geological stor- age; or (B) utilized by the taxpayer in a manner described in § 45Q(f)(5). (4) Section 45Q(a)(3) allows a credit of the applicable dollar amount (as deter- mined under § 45Q(b)(1)) per metric ton of qualified carbon oxide captured by the taxpayer using carbon capture equipment 1 Unless otherwise specified, all “section” or “§” references are to the Code or the Income Tax Regulations (26 CFR part 1). 2 Section 70522 of the OBBBA modified § 45Q to disallow the credit if the taxpayer is a specified foreign entity as defined in § 7701(a)(51)(B) of the Code or a foreign-influenced entity as defined in § 7701(a)(51)(D), determined without regard to clause (i)(II) thereof, for taxable years beginning after July 4, 2025. Section 70522 of the OBBBA also modified § 45Q to establish parity between the credit amount for the different uses and utilization of qualified carbon oxide and the credit amount for disposal in secure geological storage for facilities or equipment placed in service after July 4, 2025. Bulletin No. 2026–36 243 August 31, 2026 which is originally placed in service at a qualified facility on or after February 9, 2018, during the 12-year period beginning on the date the equipment was originally placed in service, and (i) disposed of by the taxpayer in secure geological stor- age, (ii) used by the taxpayer as a tertiary injectant in a qualified enhanced oil or nat- ural gas recovery project and disposed of by the taxpayer in secure geological stor- age, or (iii) utilized by the taxpayer in a manner described in § 45Q(f)(5). (5) Section 45Q(f)(2) directs the Sec- retary of the Treasury or the Secretary’s delegate (Secretary), in consultation with the EPA, the Secretary of Energy, and the Secretary of the Interior, to establish reg- ulations for determining adequate secu- rity measures for the geological storage of qualified carbon oxide under § 45Q(a) such that the qualified carbon oxide does not escape into the atmosphere. Sec- tion 45Q(f)(2) further provides that the term “geological storage of qualified car- bon oxide” includes storage at deep saline formations, oil and gas reservoirs, and unminable coal seams under such con- ditions as the Secretary may determine under such regulations. (6) On June 2, 2020, the Treasury Department and the IRS published a notice of proposed rulemaking (REG-112339- 19) in the Federal Register (85 F.R. 34050) under § 45Q. After consideration of all comments received in response to the proposed regulations, on January 15, 2021, the Treasury Department and the IRS, in consultation with the EPA, Depart- ment of Energy, and the Department of the Interior, published final regulations in the Federal Register under § 45Q. See T.D. 9944; 86 F.R. 4728, as corrected in 86 F.R. 16530 (March 30, 2021). (7) Section 1.45Q-3(a) provides that, in general, to qualify for the § 45Q credit, a taxpayer must either physically or con- tractually dispose of captured qualified carbon oxide in secure geological storage in the manner provided in § 1.45Q-3(b), or utilize qualified carbon oxide in a manner conforming with § 45Q(f)(5) and § 1.45Q- 4. Secure geological storage includes, but is not limited to, storage at deep saline formations, oil and gas reservoirs, and unminable coal seams. (8) Section 1.45Q-3(b) provides that for purposes of the § 45Q credit, qualified carbon oxide is considered disposed of by the taxpayer in secure geological stor- age such that the qualified carbon oxide does not escape into the atmosphere if the qualified carbon oxide is (1) injected into a well that (i) complies with applicable Underground Injection Control (UIC) or other regulations, located onshore or off- shore under submerged lands within the territorial jurisdiction of States or federal waters, and (ii) is not used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project, in compli- ance with applicable requirements under subpart RR ; or (2) injected into a well that (i) complies with applicable UIC or other regulations, is located onshore or offshore under submerged lands within the territo- rial jurisdiction of States or Federal waters, and (ii) is used as a tertiary injectant in a qualified enhanced oil or natural gas recovery project and stored in compli- ance with applicable requirements under subpart RR, or the International Organiza- tion for Standardization (ISO) standards endorsed by the American National Stan- dards Institute (ANSI) under CSA/ANSI ISO 27916:2019, Carbon dioxide capture, transportation and geological storage— Carbon dioxide storage using enhanced oil recovery (CO 2 -EOR) (CSA/ANSI ISO 27916:2019). Collectively, the storage of qualified carbon oxide at a project com- plying with the requirements of § 1.45Q- 3(b)(1) or (2) is hereinafter referred to in this notice as “secure geological storage.” (9) Section 1.45Q-2(h)(5) provides that, in general, carbon oxide that is injected into an oil reservoir that is not a qualified enhanced oil recovery project under § 43(c)(2) of the Code due to cir- cumstances such as the first injection of a tertiary injectant occurring before 1991, or because a petroleum engineer’s certifica- tion was not timely filed, cannot be treated as qualified carbon oxide, disposed of in secure geological storage, or utilized in a manner described in § 45Q(f)(5). Section 1.45Q-2(h)(5) does not apply to an oil res- ervoir if: (i) the reservoir has permanently ceased oil production; (ii) the operator has obtained a UIC Class VI permit; and (iii) the operator complies with subpart RR. (10) Section 1.45Q-3(d) provides that for a qualified enhanced oil or natural gas recovery project in which the taxpayer reported volumes of carbon oxide to the EPA pursuant to subpart RR, the taxpayer may self-certify the volume of qualified carbon oxide claimed for purposes of § 45Q. For a qualified enhanced oil or nat- ural gas recovery project in which the taxpayer determined volumes pursuant to CSA/ANSI ISO 27916:2019, a taxpayer may prepare documentation as outlined in CSA/ANSI ISO 27916:2019 internally, but all such documentation must be pro- vided to a qualified independent engineer or geologist, who then must certify that the documentation provided, including the mass balance calculations as well as information regarding monitoring and containment assurance, is accurate and complete. The qualified independent engineer or geologist certifying a project must be duly registered or certified in any State. The certification must contain an affidavit from the certifying engineer or geologist stating that he or she is indepen- dent from the taxpayer (and if an election under § 45Q(f)(3)(B) has been made, the affidavit must state that he or she is inde- pendent from both the electing taxpayer and the credit claimant). Certifications must be made annually and under pen- alties of perjury. For any leaked amount of qualified carbon oxide (as defined in § 1.45Q-5(c)) that is determined pursuant to CSA/ANSI ISO 27916:2019, the cer- tification must also include a statement that the quantity was determined in accor- dance with sound engineering principles. Taxpayers that capture and dispose of qualified carbon oxide giving rise to the § 45Q credit must file Form 8933, Carbon Oxide Sequestration Credit, with a timely filed Federal income tax return or Form 1065, U.S. Return of Partnership Income, including extensions or amendments to Federal income tax returns, Forms 1065, or on administrative adjustment requests under § 6227 (AARs), as applicable. (11) Section 1.45Q-5(a) provides that a recapture event occurs when qualified carbon oxide for which a § 45Q credit has been previously claimed ceases to be disposed of in secure geological stor- age or used as a tertiary injectant during the recapture period. The amount of such carbon oxide that is securely stored in the current year is determined according to the applicable requirements of subpart RR or CSA/ANSI ISO 27916:2019. August 31, 2026 244 Bulletin No. 2026–36 (12) Section 1.45Q-5(c) provides that the metric tons of qualified carbon oxide that has leaked to the atmosphere must be quantified pursuant to the require- ments of subpart RR or CSA/ANSI ISO 27916:2019. .02 EPA Regulations. (1) Under the Safe Drinking Water Act and regulations promulgated there- under, injection of carbon dioxide into any underground reservoir requires the operator to comply with UIC program regulations and to obtain the appropriate UIC well permits. The UIC program is designed to protect underground sources of drinking water from underground injection. Under 40 CFR 146.5 (Classifi- cation of injection wells), Class II may be an appropriate UIC well permit for wells that inject fluids (including carbon diox- ide) brought to the surface in connection with conventional oil or natural gas pro- duction and which may be commingled with waste waters from gas plants that are an integral part of production operations, unless those waters are classified as a haz- ardous waste at the time of injection, and for wells which inject fluids (including carbon oxides) for enhanced recovery of oil or natural gas. Class VI is an appropri- ate UIC well permit for wells that are not experimental in nature and that are used for geologic sequestration of carbon diox- ide beneath the lowermost formation con- taining an underground source of drinking water; for wells used for geologic seques- tration of carbon dioxide that have been granted a waiver of the injection depth requirements pursuant to requirements at 40 CFR 146.95; or for wells used for geo- logic sequestration of carbon dioxide that have received an expansion to the areal extent of an existing Class II enhanced oil recovery or enhanced gas recovery aquifer exemption pursuant to 40 CFR §§ 146.4 and 144.7(d). (2) Operators that inject carbon diox- ide underground are also subject to the EPA’s GHGRP requirements set forth at 40 CFR Part 98. Under 40 CFR Part 98, facilities that inject carbon dioxide underground for long-term containment of carbon dioxide in subsurface geologic formations are specifically subject to subpart RR (Geologic Sequestration of Carbon Dioxide source category). Facil- ities that are subject to subpart RR must report basic information on carbon diox- ide received for injection, develop and implement an EPA-approved site-spe- cific Monitoring, Reporting, and Ver- ification Plan (MRV Plan), and report the amount of carbon dioxide geologi- cally sequestered using a mass balance approach and annual monitoring activi- ties. Facilities that are subject to subpart RR include UIC Class VI wells and those UIC Class II wells that have opted into being subject to subpart RR by submit- ting a proposed MRV Plan to, and receiv- ing approval from, the EPA. Such facil- ities are required to prepare and submit reports on a calendar year basis (Annual Reports). (3) Annual Reports generally must be submitted no later than March 31 of each calendar year for greenhouse gas emissions in the previous calendar year. 40 CFR § 98.3(b). Annual Reports are required to be submitted electronically in a format specified by the Administrator of the EPA. 40 CFR § 98.5(a). The EPA generally requires Annual Reports to be submitted through the EPA’s electronic reporting system, e-GGRT. Historically, the EPA has launched the e-GGRT system in mid-February for a given reporting year. See EPA, Extending the Reporting Dead- line Under the Greenhouse Gas Report- ing Rule for 2024 Data, 90 F.R. 13085, 13087 (March 20, 2025). Annual Reports undergo verification by the EPA, and non-confidential data from these reports are published on the EPA’s website. (4) On September 16, 2025, the EPA issued proposed regulations, Reconsider- ation of the Greenhouse Gas Reporting Program, 90 F.R. 44591, proposing to amend the GHGRP to remove program obligations for most source categories, including the obligations in subpart RR, for reporting years after 2024. The pro- posed regulations would also revise 40 CFR Part 98 subpart A to extend the Part 98 (including subpart RR) reporting dead- line for reporting year 2025 from March 31, 2026, to June 10, 2026. The EPA has proposed that the amendments, if final- ized, would become effective within sixty days of publication in the Federal Reg- ister. Because the proposed amendments would remove the reporting obligations under subpart RR following reporting year 2024, reporters would cease submit- ting Annual Reports within sixty days of publication of the final rule in the Federal Register. 90 F.R. at 44603. (5) On February 27, 2026, the EPA issued a final rule extending the deadline for Annual Reports for reporting year 2025 to October 30, 2026. See Extending the Reporting Deadline Under the Green- house Gas Reporting Rule for 2025, 91 F.R. 9712. .02 Modification of Section 3 of Notice 2026-1. This section 3.02 modifies and amplifies section 3 of Notice 2026-1 by revising sections 3.01 and 3.02(1), (2), and (3), and adding new section 3.02(4). These changes expand the applicabil- ity of the safe harbor provided in Notice 2026-1 to (1) qualified carbon oxide that is stored (i) at a qualified enhanced oil or natural gas recovery project for which the taxpayer received an EPA-approved MRV plan, and (ii) in compliance with the applicable requirements of subpart RR as in effect on December 31, 2025, and (2) the determination of the amount of quali- fied carbon oxide securely stored, and the amount of qualified carbon oxide that has leaked into the atmosphere, for purposes of satisfying the recapture requirements of § 1.45Q-5(a) and (c). As so modified and amplified, section 3 of Notice 2026-1 now reads as follows: SECTION 3. SAFE HARBOR FOR SECURE GEOLOGICAL STORAGE OCCURRING ON OR AFTER JANUARY 1, 2025 .01 In General. This section describes a safe harbor (Safe Harbor) that taxpayers may use for certain reporting years in which secure geological storage occurs (relevant reporting year) to satisfy the requirements of § 1.45Q-3(b)(1)(ii), § 1.45Q-3(b)(2) (ii), or § 1.45Q-2(h)(5)(iii), as applica- ble, § 1.45Q-3(d), and § 1.45Q-5(a) and (c), in the event the EPA does not launch the e-GGRT by March 31 of the calendar year immediately following the relevant reporting year (e-GGRT Unavailability). The Safe Harbor does not apply in the event the EPA launches the e-GGRT for the relevant reporting year by March 31 of the calendar year immediately following the relevant reporting year. .02 Safe Harbor for Secure Geological Storage. Bulletin No. 2026–36 245 August 31, 2026 (1) In General. Taxpayers following the guidance set forth in section 3.02(2), (3), and (4) of this notice will be consid- ered to have satisfied: (i) the requirements in § 1.45Q-3(b)(1)(ii), § 1.45Q-3(b)(2) (ii), or § 1.45Q-2(h)(5)(iii), as applicable, related to subpart RR (§ 45Q Subpart RR Requirements); (ii) the requirements of § 1.45Q-3(d) (Certification Requirements); and (iii) the requirements of § 1.45Q-5(a) and (c) related to determining the amount of qualified carbon oxide securely stored and the quantity of qualified carbon oxide leaked to the atmosphere (Recapture Requirements). (2) Compliance with § 45Q Subpart RR Requirements. In the case of e-GGRT Unavailability for a relevant reporting year, the taxpayer performing secure geo- logical storage in such reporting year will be considered to have satisfied the § 45Q Subpart RR Requirements for such report- ing year if: (i) such storage complies with the applicable requirements of subpart RR as in effect on December 31, 2025; (ii) the taxpayer received an EPA-approved MRV plan for such project and the MRV plan is applicable to the dates of such stor- age; and (iii) instead of submitting the Annual Report for the relevant reporting year with respect to such storage through the e-GGRT pursuant to 40 CFR §§ 98.3 and 98.5, the taxpayer prepares and sub- mits the Annual Report to an independent engineer or geologist, who certifies the Annual Report, in the manner specified in section 3.02(3)(A) and (B) of this notice. The Annual Report must contain all of the information and documentation, includ- ing mass balance accounting calculations and monitoring and containment assur- ance, that would have been required under subpart RR as in effect on December 31, 2025. (3) Compliance with Certification Requirements. In the event of e-GGRT Unavailability for a relevant reporting year, the taxpayer performing secure geo- logical storage will be considered to have satisfied the Certification Requirements if the taxpayer satisfies the requirements of section 3.02(3)(A) and (B) of this notice with respect to such storage. (A) The taxpayer must submit the Annual Report for the relevant reporting year to a qualified independent engineer or geologist. The qualified independent engineer or geologist certifying the infor- mation must be duly registered or certified in any State. (B) The qualified independent engineer or geologist must certify that (i) the cap- ture and disposal described in § 1.45Q- 3(b)(1), § 1.45Q-3(b)(2), or § 1.45Q-2(h) (5), as applicable, is in compliance with subpart RR as in effect on December 31, 2025, and (ii) the information and docu- mentation contained in the Annual Report for the relevant reporting year is accurate and complete based upon the require- ments under subpart RR as in effect on December 31, 2025. The certification must contain an affidavit from the certify- ing engineer or geologist stating that he or she is independent from the taxpayer (and if an election under § 45Q(f)(3)(B) has been made, the affidavit must state that he or she is independent from both the elect- ing taxpayer and the credit claimant). The certification must be made under penalties of perjury. (4) Compliance with Recapture Requirements. In the event of e-GGRT Unavailability for a relevant reporting year, a taxpayer will be considered to have satisfied the Recapture Requirements with respect to any secure geological storage subject to the Recapture Requirements if the Annual Report for reporting year 2025 or later, certified in the manner specified in section 3.02(3) of this notice, includes the following determinations pursuant to the applicable requirements of subpart RR as in effect on December 31, 2025: (i) the quantity of qualified carbon oxide that is securely stored for the calendar year; and (ii) the quantity, if any, in metric tons of qualified carbon oxide that has leaked into the atmosphere in such reporting year. .03 Timely reporting. Taxpayers that capture and dispose of qualified carbon oxide giving rise to the § 45Q credit must file a Form 8933 with a timely filed Fed- eral income tax return or Form 1065, including extensions, or amendments to Federal income tax returns, Forms 1065, or on AARs, as applicable. To rely upon the Safe Harbor, a taxpayer must complete all documentation and obtain the certifica- tion described in section 3.02(2) and (3) of this notice by the time it (or, if an election under § 45Q(f)(3)(B) has been made, any credit claimant) timely files its relevant tax return, as described in the preceding sentence. Taxpayers should retain the doc- umentation and certification described in section 3.02(2) and (3) of this notice in their books and records pursuant to § 6001. See also T.D. 9944; 86 F.R 4728, 4758-59. .03 Modification of Section 5 of Notice 2026-1. This section 3.03 modifies and amplifies section 5 of Notice 2026-1 by extending the applicability of the Safe Harbor to secure geological storage occur- ring on or after January 1, 2025, and on or before December 31 of the calendar year in which the Treasury Department and the IRS publish further interim guidance in the Internal Revenue Bulletin or forth- coming proposed regulations in the Fed- eral Register addressing compliance with measurement, reporting, and verification requirements under § 45Q for secure geo- logical storage. As so modified and ampli- fied, section 5 of Notice 2026-1 now reads as follows: SECTION 5. APPLICABILITY DATE This notice applies to secure geologi- cal storage occurring on or after January 1, 2025, and on or before December 31 of the calendar year in which the Treasury Department and the IRS publish further interim guidance in the Internal Revenue Bulletin or forthcoming proposed regu- lations in the Federal Register address- ing compliance with requirements under § 45Q for secure geological storage. Tax- payers claiming the § 45Q credit for secure geological storage occurring on or after January 1, 2025, and on or before Decem- ber 31 of the calendar year in which the Treasury Department and the IRS publish such guidance or forthcoming proposed regulations may rely upon this notice to satisfy the requirements of § 1.45Q-3(b) (1)(ii), 1.45Q-3(b)(2)(ii), or 1.45Q-2(h) (5)(iii), as applicable, § 1.45Q-3(d), and §1.45Q-5(a) and (c). SECTION 4. REQUEST FOR COMMENTS .01 Request for Comments. The Treasury Department and the IRS, in consultation with the Administrator of the EPA, the Secretary of Energy, and the Secretary of the Interior, request comments on the appropriate standard to be used in August 31, 2026 246 Bulletin No. 2026–36 place of subpart RR to demonstrate com- pliance with § 45Q for secure geological storage. In particular, the Treasury Depart- ment and the IRS request comments on whether the International Organization for Standardization’s standard 27914:2026— Carbon dioxide capture, transportation and storage—Geological storage (Ed. 2, 2026), which was published in March 2026, could be used as an alternative, including the verification methods set forth therein. In addition, the Treasury Department and the IRS request comments on whether there are other processes or methodologies that could serve as suitable alternatives to sub- part RR in the event the EPA finalizes its regulations as proposed. .02 Deadline for Submission. Written comments should be submitted by October 30, 2026. However, consid- eration will be given to any written com- ments submitted after October 30, 2026, if such consideration will not delay the issu- ance of future published guidance. .03 Form and Manner. The subject line for the comments should include a reference to Notice 2026- 50. All stakeholders are strongly encour- aged to submit comments electronically. Comments may be submitted in one of two ways: (1) Electronically via the Federal eRulemaking Portal at https://www.reg- ulations.gov (type IRS-2026-0728 in the search field on the https://www.regula- tions.gov homepage to find this notice and submit comments). (2) By mail to: Internal Revenue Ser- vice, CC:PA:01:PR (Notice 2026-50), Room 5503, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. .04 Publication of Comments. The Treasury Department and the IRS will publish for public availability any comment submitted electronically or on paper to the IRS’s public docket on https:// www.regulations.gov. SECTION 5. EFFECT ON OTHER DOCUMENTS This notice modifies and amplifies Notice 2026-1. SECTION 6. DRAFTING INFORMATION The principal author of this notice is the Office of Associate Chief Counsel (Energy, Credits, and Excise Tax). For further information regarding this notice contact (202) 317-6853 (not a toll-free number). Bulletin No. 2026–36 i August 31, 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. August 31, 2026 ii Bulletin No. 2026–36 Numerical Finding List 1 Bulletin 2026–36 Announcements: 2026-11, 2026-29 I.R.B. 49 2026-12, 2026-29 I.R.B. 50 2026-13, 2026-32 I.R.B. 173 2026-14, 2026-34 I.R.B. 180 2026-15, 2026-35 I.R.B. 214 Notices: 2026-39, 2026-27 I.R.B. 1 2026-38, 2026-28 I.R.B. 30 2026-40, 2026-28 I.R.B. 33 2026-41, 2026-29 I.R.B. 39 2026-42, 2026-29 I.R.B. 41 2026-43, 2026-29 I.R.B. 42 2026-21, 2026-30 I.R.B. 51 2026-44, 2026-32 I.R.B. 143 2026-28, 2026-34 I.R.B. 177 2026-46, 2026-35 I.R.B. 182 2026-48, 2026-35 I.R.B. 185 2026-49, 2026-35 I.R.B. 198 2026-50, 2026-36 I.R.B. 242 Revenue Procedures: 2026-25, 2026-29 I.R.B. 45 2026-18, 2026-30 I.R.B. 53 2026-26, 2026-31 I.R.B. 131 2026-32, 2026-32 I.R.B. 146 2026-28, 2026-33 I.R.B. 175 2026-30, 2026-35 I.R.B. 212 Revenue Rulings: 2026-12, 2026-28 I.R.B. 27 2026-13, 2026-32 I.R.B. 132 2026-14, 2026-35 I.R.B. 181 2026-15, 2026-36 I.R.B. 216 2026-16, 2026-36 I.R.B. 237 Treasury Decisions: 10051, 2026-31 I.R.B. 118 10052, 2026-31 I.R.B. 121 10050, 2026-32 I.R.B. 134 10053, 2026-36 I.R.B. 237 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin 2025–52, dated December 21, 2025. Bulletin No. 2026–36 iii August 31, 2026 Finding List of Current Actions on Previously Published Items 1 Bulletin 2026–36 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2026–27 through 2026–52 is in Internal Revenue Bulletin 2025–52, dated December 21, 2025. 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 www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.
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