Internal Revenue Bulletin 2026-22 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2026–22
May 26, 2026
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2026-23, page 1542.
This Revenue Procedure provides issuers of qualified mort-
gage bonds and mortgage credit certificates with (1) the
nationwide average purchase price for residences located in
the United States, and (2) the average area purchase price
safe harbors for residences located in statistical areas in
each state, the District of Columbia, Puerto Rico, the North-
ern Mariana Islands, American Samoa, the Virgin Islands, and
Guam.
Rev. Rul. 2026-10, page 1515.
Interest rates: underpayments and overpayments. The rates
for interest determined under Section 6621 of the code for
the calendar quarter beginning July 1, 2026, will be 7 per-
cent for overpayments (6 percent in the case of a corpora-
tion), 7 percent for underpayments, and 9 percent for large
corporate underpayments. The rate of interest paid on the
portion of a corporate overpayment exceeding $10,000 will
be 4.5 percent.
EMPLOYEE PLANS
TD 10046, page 1512.
This document contains final regulations providing that
amounts paid to a member of an Indian Tribe as remu-
neration for services performed in a fishing rights-related
activity may be treated as compensation for purposes of
applying the limits on qualified retirement plan benefits
and contributions. These regulations affect participants
who perform fishing rights-related activities and their
beneficiaries, and sponsors and administrators of Tribal
plans.
INCOME TAX
Notice 2026-29, page 1537.
This notice publishes the inflation adjustment factor for the
carbon oxide sequestration credit under § 45Q for calendar
year 2026. The inflation adjustment factor is used to deter-
mine the amount of the credit allowable under § 45Q for
taxpayers that make an election under § 45Q(b)(3) to have
the dollar amounts applicable under § 45Q(a)(1) or (2) apply.
Notice 2026-30, page 1539.
This notice publishes the reference price under § 45K(d)(2)
(C) of the Internal Revenue Code for calendar year 2025.
The reference price applies in determining the amount of
the enhanced oil recovery credit under § 43, the marginal
well production credit under § 45I, and the percentage
depletion in case of oil and natural gas produced from mar-
ginal properties under § 613A.
Rev. Proc. 2026-21, page 1538.
This revenue procedure establishes a significant issue ruling
program to allow taxpayers to request rulings on one or more
issues that (1) are solely under the jurisdiction of the Associate
Chief Counsel (Corporate), (2) are significant, and (3) involve
the tax consequences or characterization of a transaction (or
part of a transaction) that is described in § 332, 351, 355,
368, or 1036. Rev. Proc. 2026-1, 2026-1 I.R.B. 1, and Rev.
Proc. 2026-3, 2026-1 I.R.B. 143, are modified and amplified.
Rev. Proc. 2026-22, page 1541.
This revenue procedure provides indexing adjustments for
the applicable dollar amounts under section 4980H(c)(1) and
(b)(1) of the Internal Revenue Code. These indexed amounts
are used to calculate the employer shared responsibility pay-
ments under section 4980H(a) and (b)(1), respectively.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
May 26, 2026 Bulletin No. 2026–22

Part I
1.415(a)-1(g)(5); 1.415(c)-2(g)(9)
TD 10046
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Treatment of Income
from Indian Fishing
Rights-Related Activity as
Compensation
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final Regulations.
SUMMARY: This document contains
final regulations providing that amounts
paid to a member of an Indian Tribe as
remuneration for services performed in
a fishing rights-related activity may be
treated as compensation for purposes of
applying the limits on qualified retirement
plan benefits and contributions. These reg-
ulations affect participants, beneficiaries,
sponsors, and administrators of Tribal
plans.
DATES: Effective Date: These regula-
tions are effective on May 4, 2026.
Applicability Date: For date of applicabil-
ity, see §1.415(a)-1(g)(5).
FOR FURTHER INFORMATION
CONTACT: Jamie Dvoretzky at (202)
317-4102, or Pamela Kinard at (202) 317-
6000 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Authority
This Treasury Decision contains final
regulations that amend the Income Tax
Regulations (26 CFR part 1) under sec-
tion 415, related to the definition of the
term “compensation” for purposes of
contribution and benefit limits applicable
to qualified retirement plans. These final
regulations are issued under the authority
granted by section 415(j) of the Internal
Revenue Code (Code), which authorizes
the Secretary of the Treasury or his dele-
gate (Secretary) to prescribe such regula-
tions as may be necessary to carry out the
purposes of section 415. These final regu-
lations are also issued under the authority
granted by section 7805(a), which autho-
rizes the Secretary to prescribe all needful
rules and regulations for the enforcement
of the Code.
Background
This document contains amendments
to regulations under section 415 of the
Code, which generally imposes limita-
tions on the annual amount that a qualified
retirement plan may provide, with respect
to a participant, in either benefit payments
or in contributions and other additions to
the plan. These limitations generally are
based on a participant’s compensation.
Section 415(c)(3) provides that the term
“participant’s compensation” means the
compensation of the participant from the
employer for the year.
Section 1.415(c)-2(a) of the Income
Tax Regulations generally provides that
compensation from the employer within
the meaning of section 415(c)(3) includes
all items of remuneration described in
§1.415(c)-2(b) to the extent that the
amounts are includible in gross income,
but excludes the items of remuneration
described in §1.415(c)-2(c), such as con-
tributions made by an employer to a plan
of deferred compensation to the extent
that the contributions are not includible in
the gross income of the employee for the
taxable year in which contributed.
Section 7873(a)(1) provides that no
tax shall be imposed on income derived
from a fishing rights-related activity of
an Indian tribe by (A) a member of the
Indian tribe directly or through a quali-
fied Indian entity, or (B) a qualified Indian
entity. Section 7873(a)(2) provides that
no employment tax shall be imposed on
remuneration paid for services performed
in a fishing rights-related activity of an
Indian tribe by a member of such tribe
for another member of such tribe or for a
qualified Indian entity.
On November 15, 2013, proposed
regulations under section 415 were pub-
lished in the Federal Register (78 FR
68780). The proposed regulations would
provide that income described in section
7873(a) (“fishing rights-related income”)
is included in the definition of compensa-
tion under section 415. Specifically, the
proposed regulations would provide that
amounts paid to a member of an Indian
tribe as remuneration for services per-
formed in a fishing rights-related activity
(as defined in section 7873(b)(1)) do not
fail to be treated as compensation under
§1.415(c)-2(b)(1) and (b)(2) (and are not
excluded from the definition of compensa-
tion pursuant to §1.415(c)-2(c)(4)) merely
because those amounts are not subject to
income tax or employment taxes as a result
of section 7873(a)(1) and (a)(2). Thus, the
determination of whether an amount con-
stitutes wages, salaries, or earned income
for purposes of §1.415(c)-2(b)(1) or (b)(2)
is made without regard to the exemption
from income tax under section 7873(a)(1)
or employment tax under section 7873(a)
(2). In addition, by permitting fishing
rights-related income to be treated as
wages, salaries, or earned income under
§1.415(c)-2(b)(1) and (b)(2), plans that
accept contributions of fishing rights-
related income would not be precluded
from utilizing the safe harbor definitions
of compensation under §1.415(c)-2(d)(2)
and (d)(3).
Written comments on the proposed
regulations were received and considered.
The Department of the Treasury (Trea-
sury Department) and the IRS did not
receive any requests for a public hearing
to address the proposed regulations, and,
accordingly, no hearing was held. The
Treasury Department held a Tribal con-
sultation on this proposed rule on Decem-
ber 17, 2013. Additionally, on August 22,
2024, the Treasury Department met with
the Treasury Tribal Advisory Committee,
Subcommittee on Parity and Reform and
received additional feedback on the pro-
posed regulations. After consideration of
the comments received, the proposed reg-
ulations are adopted by this Treasury deci-
sion without material modification.
May 26, 2026 1512 Bulletin No. 2026–22

Summary of Comments and
Explanation of Provisions
A. Treatment of Fishing Rights-Related
Income as Compensation under Section
415
The proposed regulations were issued
primarily in response to requests from
the Tribal community that the Treasury
Department and the IRS address whether
contributions can be made to quali-
fied retirement plans based on fishing
rights-related income. Under the proposed
regulations, fishing rights-related income
would not fail to be treated as compen-
sation under §1.415(c)-2(b)(1) and (b)(2)
(and is not excluded from the definition of
compensation pursuant to §1.415(c)-2(c)
(4)) merely because those amounts are not
subject to income tax or employment tax
as a result of section 7873(a)(1) or (a)(2).
Commenters generally reacted favor-
ably to this proposed rule, stating that
the proposed regulations provided much
needed clarity on how plans should treat
fishing rights-related income paid to
employees subject to section 7873 (Tribal
employees) under section 415. The Trea-
sury Department and the IRS also received
comments stating that additional guid-
ance is needed with respect to a variety
of issues relating to fishing rights- related
income in retirement plans. Many of these
issues are outside the scope of these regu-
lations, which are modifying the definition
of compensation for purposes of section
415, and so the text of the final regulations
does not address them. However, this pre-
amble (under the headings “Taxation of
Distributions,” “Treating Contributions as
Roth Contributions,” and “Self-Employed
Tribal Members” in this Summary of
Comments and Explanation of Provisions)
provides clarifying information relating to
many of these issues.
B. Taxation of Distributions
The preamble to the proposed regula-
tions requested comments regarding the
taxation of qualified plan distributions
attributable to contributions based on fish-
ing rights-related income, and the appli-
cation of section 72(f)(2)
1
to such distri-
butions. All of the comments received
requested that distributions attributable
to contributions based on fishing rights-
related income should not be taxable to a
Tribal employee.
Several of the commenters referred
to Hall v. Commissioner, 76 T.C.M. 473
(1998), in which the petitioner was a
full-time employee in a Tribal fish hatch-
ery who received a choice between an
employer contribution to a retirement
account or an employer contribution to a
health plan. In 1992, the petitioner elected
the retirement benefit and the employer
contributed a monthly amount to an indi-
vidual retirement account (IRA). That
same year, the petitioner received early
distributions from the IRA attributable
to those employer contributions and to
income earned in the IRA. The Tax Court
generally found that, under section 72 (as
modified by section 408(d)(1) and (2)), the
amount of the distributions attributable to
contributions based on fishing rights-
related income represents a nontaxable
return of his investment in the contract,
but added that the amount of distributions
attributable to the earnings on the IRA
contributions represents accrued income
that is taxable to the petitioner.
In response to the requests to clarify
the taxation of qualified plan distributions
attributable to contributions based on fish-
ing rights-related income, the Treasury
Department and the IRS have determined
that the holding in Hall v. Commissioner
should apply to these distributions. Thus,
consistent with Hall, any contribution to
a qualified retirement plan that is attrib-
utable to remuneration for services per-
formed by a Tribal employee in a fishing
rights-related activity is treated as invest-
ment in the contract for a plan participant
under the rules of section 72(f)(2). There-
fore, any distribution of such amounts is
nontaxable to the participant. However,
also consistent with Hall, the amount of
the distribution attributable to earnings on
those contributions is taxable.
Another commenter raised an issue
regarding the ordering for determining
the taxable and nontaxable amounts of
a qualified retirement plan distribution.
Referring to qualified retirement plan
distributions attributable to fishing rights-
related income, this commenter suggested
that plan participants be allowed to elect
the order in which the qualified retirement
plan distributions are made so that the non-
taxable amounts could be received first.
This suggestion is not adopted because
it is inconsistent with the basis recovery
rules in section 72.
2
Tribal employees will
have investment in the contract on contri-
butions to the plan attributable to fishing
rights-related income, and thus the gen-
eral basis recovery rules of section 72 will
apply.
The Treasury Department and the
IRS also received comments concerning
the treatment of earnings on contribu-
tions attributable to fishing rights-related
income and the treatment of employer
matching and profit-sharing contributions
related to contributions attributable to fish-
ing rights-related income. As explained in
the preceding paragraph, section 72 pro-
vides basis recovery rules for determin-
ing the taxable and nontaxable portions
of a distribution. Section 72(f) applies to
amounts contributed by the employer and
does not distinguish employer matching
or employer profit-sharing contributions
from employee elective deferrals (which
are treated as employer contributions pur-
suant to section 402(e)(3)). Therefore, sec-
tion 72(f)(2) applies not only to employee
elective deferrals but also to employer
matching and employer profit-sharing
contributions attributable to remunera-
tion for services performed by a Tribal
employee in a fishing rights-related activ-
ity. As explained in Hall v. Commissioner,
however, section 72(f)(2) does not apply
to earnings. Therefore, qualified retire-
ment plan distributions attributable to the
earnings on contributions based on fish-
ing rights-related income generally will
1
Section 72(f)(2) treats employer contributions as investment in the contract if those amounts would not have been includible in income of the employee had they been paid directly to the
employee.
2
Section 72(b) provides that gross income does not include that part of any amount received as an annuity which bears the same ratio to such amount as the investment in the contract bears
to the expected return under the contract.
Bulletin No. 2026–22 1513 May 26, 2026

May 26, 2026 1514 Bulletin No. 2026–22
be taxable to the participant and the basis
recovery rules of section 72 will apply in
determining the portion of a distribution
that is includible in income.
C. Treating Contributions as Roth
Contributions
One commenter suggested that guid-
ance be provided to allow a qualified
retirement plan to treat contributions
attributable to fishing rights-related
income as either Roth contributions or
after-tax contributions. The commenter
added that the guidance could provide
that, if the plan permits participants
to make Roth contributions, then the
employee’s contributions attributable to
fishing rights-related income would be
treated as Roth contributions. If the plan
does not provide for Roth contributions,
then these contributions would be treated
as after-tax contributions.
Section 1.401(k)-1(f)(2) provides
that if an elective contribution would not
have been includible in gross income if
the amount had been paid directly to the
employee (rather than being subject to a
cash or deferred election), the elective con-
tribution is nevertheless permitted to be a
designated Roth contribution, provided the
employee is entitled to treat the amount as
an investment in the contract pursuant to
section 72(f)(2). As previously stated in this
preamble under the heading “Taxation of
Distributions,” any contributions attribut-
able to remuneration for services performed
in a fishing rights-related activity are treated
as investment in the contract for the plan
participant under the rules of section 72(f)
(2). Therefore, contributions attributable to
fishing rights-related income are permitted
to be designated Roth contributions under a
qualified retirement plan that permits partic-
ipants to make those contributions.
D. Self-Employed Tribal Members
Two commenters asked about the retire-
ment plan options for Tribal members who
earn fishing rights-related income but who
may not be employed by an Indian tribe.
Section 401(a) provides that a plan of an
employer is a qualified plan only if it is cre-
ated or organized for the exclusive benefit
of the employer’s employees or their ben-
eficiaries. For these purposes, whether an
individual is an employee of the employer
maintaining a plan is generally determined
under common law principles. See Nation-
wide Mutual Insurance Co. v. Darden, 503
U.S. 318 (1992). Self-employed individu-
als generally may not participate in a qual-
ified retirement plan sponsored by another
employer. Moreover, whether an individual
earns fishing-rights related income is not
determinative of whether that individual is
an employee. However, an individual who
is self-employed under section 401(c)(1)
may nevertheless maintain his or her own
qualified retirement plan, such as a section
401(k) plan.
E. Additional Comments
Commenters also requested guidance
on several other issues, including guidance
permitting rollover of contributions attrib-
utable to fishing rights-related income from
a nonqualified plan to a qualified plan, guid-
ance permitting Tribal employers to take
retroactive action to permit Tribal employ-
ees to contribute fishing rights-related
income to a qualified plan, and guidance
on testing for contributions attributable to
fishing rights-related income. These com-
ments are all beyond the scope of these reg-
ulations and, in certain cases, the requested
guidance may not be permissible under the
Code (for example, rollover of amounts
from a nonqualified plan into a qualified
plan). However, the Treasury Department
and IRS will continue to review comments
that are beyond the scope of these regula-
tions and consider if any further guidance
is needed. If additional guidance is needed,
the Treasury Department and the IRS will
conduct Tribal consultation pursuant to
Executive Order 13175.
Applicability Date
These final regulations apply for plan
years ending on or after May 4, 2026.
Special Analyses
I. Regulatory Planning and Review
OMB’s Office of Information and Reg-
ulatory Affairs has determined that this
regulation is not significant and is not sub-
ject to review under section 6(b) of Exec-
utive Order 12866, as amended.
II. Regulatory Flexibility Act
It is hereby certified that these final
regulations will not have a significant
economic impact on a substantial num-
ber of small entities within the mean-
ing of section 601(6) of the Regulatory
Flexibility Act (5 U.S.C. chapter 6). This
certification is based on the fact that only
5,000 to 6,000 employees nationwide are
estimated to earn fishing rights-related
income. Therefore, a regulatory flexibility
analysis under the Regulatory Flexibility
Act is not required.
Pursuant to section 7805(f) of the Code,
the proposed regulations that preceded
these final regulations were submitted to
the Chief Counsel for the Office of Advo-
cacy of the Small Business Administration
for comment on their impact on small busi-
ness, and no comments were received.
Consultation and Coordination With
Tribal Governments
In addition to written comments
responding to the proposed regulations,
these final regulations reflect comments
provided in a Tribal consultation held on
December 17, 2013, as well as comments
provided in a meeting with members of
the Treasury Tribal Advisory Committee
Subcommittee on Parity and Reform on
August 22, 2024.
Drafting Information
The principal author of these regula-
tions is Jamie Dvoretzky, Office of Asso-
ciate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the Treasury Department and the IRS par-
ticipated in the development of these reg-
ulations.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Adoption of Amendments to the
Regulations
Accordingly, the Treasury Department
and the IRS amend 26 CFR part 1 as fol-
lows:

Bulletin No. 2026–22 1515 May 26, 2026
PART 1–INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as fol-
lows:
Authority: 26 U.S.C. 7805 * * *
* * * * *
Par. 2. Section 1.415(a)-1 is amended
by adding paragraph (g)(5) to read as fol-
lows:
§1.415(a)-1 General rules with
respect to limitations on benefits and
contributions under qualified plans.
* * * * *
(g) * * *
(5) Special effective date. Section
1.415(c)-2(g)(9) applies for plan years
ending on or after May 4, 2026.
Par. 3. Section 1.415(c)-2 is amended
by adding paragraph (g)(9) to read as fol-
lows:
§1.415(c)-2 Compensation.
* * * * *
(g) * * *
(9) Income derived by Indians from
exercise of fishing rights-related activ-
ities. Amounts paid to a member of an
Indian tribe directly or through a quali-
fied Indian entity (within the meaning of
section 7873(b)(3)) as compensation for
services performed in a fishing rights-
related activity (as defined in section
7873(b)(1)) of the tribe do not fail to con-
stitute compensation under paragraphs
(b)(1) and (2) of this section (and are not
excluded from the definition of compen-
sation pursuant to paragraph (c)(4) of this
section) merely because those amounts
are not subject to income or employment
taxes as a result of section 7873(a)(1)
and (a)(2). Thus, the determination of
whether an amount constitutes wages,
salaries, or earned income for purposes
of paragraph (b)(1) or (2) of this section
is made without regard to the exemption
from taxation under section 7873(a)(1)
and (a)(2).
Frank J. Bisignano,
Chief Executive Officer.
Approved: April 1, 2026.
Kenneth J. Kies,
Assistant Secretary of the Treasury
(Tax Policy).
(Filed by the Office of the Federal Register May 1,
2026, 8:45 a.m., and published in the issue of the
Federal Register for May 4, 2026, 91 FR 23915)
Section 6621.—
Determination of Rate of
Interest
26 CFR 301.6621-1: Interest rate.
Rev. Rul. 2026-10
Section 6621 of the Internal Revenue
Code establishes the interest rates on over-
payments and underpayments of tax. Under
section 6621(a)(1), the overpayment rate is
the sum of the federal short-term rate plus
3 percentage points (2 percentage points in
the case of a corporation), 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 percentage 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 determined
in accordance with section 1274(d) during
April 2026 is the rate published in Reve-
nue Ruling 2026-9, 2026-19 IRB 897, to
take effect beginning May 1, 2026. The
federal short-term rate, rounded to the
nearest full percent, based on daily com-
pounding determined during the month
of April 2026 is 4 percent. Accordingly,
an overpayment rate of 7 percent (6 per-
cent in the case of a corporation) and an
underpayment rate of 7 percent are estab-
lished for the calendar quarter beginning
July 1, 2026. The overpayment rate for
the portion of a corporate overpayment
exceeding $10,000 for the calendar quar-
ter beginning July 1, 2026, is 4.5 percent.
The underpayment rate for large corporate
underpayments for the calendar quarter
beginning July 1, 2026, is 9 percent. These
rates apply to amounts bearing interest
during that calendar quarter.
Sections 6654(a)(1) and 6655(a)(1) pro-
vide 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 underpay-
ments for the third calendar quarter begin-
ning July 1, 2026. In addition, pursuant to
section 6603(d)(4), the rate of interest on
section 6603 deposits is 4 percent for the
third calendar 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.

May 26, 2026 1516 Bulletin No. 2026–22
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 Asso-
ciate Chief Counsel (Procedure and Admin-
istration). For further information regarding
this revenue ruling, contact Mr. Conrad at
(202) 317-6844 (not a toll-free number).

Bulletin No. 2026–22 1517 May 26, 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

May 26, 2026 1518 Bulletin No. 2026–22
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. 2026–22 1519 May 26, 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

May 26, 2026 1520 Bulletin No. 2026–22
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. 2026–22 1521 May 26, 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

May 26, 2026 1522 Bulletin No. 2026–22
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, 1997
8%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. 2026–22 1523 May 26, 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

May 26, 2026 1524 Bulletin No. 2026–22
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. 2026–22 1525 May 26, 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

May 26, 2026 1526 Bulletin No. 2026–22
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%67
621
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. 2026–22 1527 May 26, 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, 2013
2%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

May 26, 2026 1528 Bulletin No. 2026–22
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

Bulletin No. 2026–22 1529 May 26, 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, 1999
9%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

May 26, 2026 1530 Bulletin No. 2026–22
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. 2026–22 1531 May 26, 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

May 26, 2026 1532 Bulletin No. 2026–22
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

Bulletin No. 2026–22 1533 May 26, 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, 2003
2.5%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

May 26, 2026 1534 Bulletin No. 2026–22
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. 2026–22 1535 May 26, 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

May 26, 2026 1536 Bulletin No. 2026–22
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
* 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. 2026–22 1537 May 26, 2026
Part III
Credit for Carbon Oxide
Sequestration 2026
Section 45Q Inflation
Adjustment Factor
Notice 2026-29
SECTION 1. PURPOSE
This notice publishes the inflation
adjustment factor for the credit for car-
bon oxide sequestration under § 45Q of
the Internal Revenue Code (§ 45Q credit)
for calendar year 2026.
1
The inflation
adjustment factor is used to determine
the amount of the credit allowable under
§ 45Q for taxpayers that make an elec-
tion under § 45Q(b)(3) to have the dollar
amounts applicable under § 45Q(a)(1) or
(2) apply.
SECTION 2. BACKGROUND
Section 45Q was added to the Code
by § 115 of the Energy Improvement and
Extension Act of 2008, enacted as Divi-
sion B of Pub. L. 110-343, 122 Stat. 3765,
3829 (October 3, 2008), to provide a credit
for the sequestration of carbon dioxide.
Section 45Q was amended by § 1131 of
the American Recovery and Reinvestment
Tax Act of 2009, enacted as Division B of
Pub. L. 111-5, 123 Stat 115 (February 17,
2009), § 41119 of the Bipartisan Budget
Act of 2018 (BBA), Pub. L. No. 115-123
(February 9, 2018), § 121 of the Taxpayer
Certainty and Disaster Tax Relief Act of
2020, enacted as Division EE of the Con-
solidated Appropriations Act, 2021, Pub.
L. 116-260, 134 Stat. 3051 (December
27, 2020), § 13104 of Pub. L. 117-169,
136 Stat. 1818 (August 16, 2022), com-
monly known as the Inflation Reduction
Act (IRA), and § 70522 of Pub. L. 119-
21, 139 Stat. 72 (July 4, 2025), commonly
known as the One, Big, Beautiful Bill Act
(OBBBA).
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 the date of the enactment of the
BBA, (ii) disposed of by the taxpayer in
secure geological storage, and (iii) not
used by the taxpayer as a tertiary injectant
in a qualified enhanced oil or natural gas
recovery project.
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 orig-
inally placed in service at a qualified
facility before the date of the enactment
of the BBA, and (ii) either (I) used by the
taxpayer as a tertiary injectant in a quali-
fied enhanced oil or natural gas recovery
project and disposed of by the taxpayer in
secure geological storage or (II) utilized
by the taxpayer in a manner described in
§ 45Q(f)(5).
Section 45Q(b)(3) provides that, for
purposes of determining the carbon oxide
sequestration credit under this section,
a taxpayer may elect to have the dollar
amounts applicable under § 45Q(a)(1)
or (2) apply in lieu of the dollar amounts
applicable under § 45Q(a)(3) or (4) for
each metric ton of qualified carbon oxide
which is captured by the taxpayer using
carbon capture equipment which is origi-
nally placed in service at a qualified facil-
ity on or after the date of the enactment of
the BBA.
Notice 2022-38 provided that 2022
was the final calendar year for which a
taxpayer may claim a § 45Q credit under
§ 45Q(a)(1) and (2) for qualified carbon
oxide that is captured by carbon capture
equipment originally placed in service at a
qualified facility before the date of enact-
ment of the BBA. Therefore, the inflation
adjustment amounts in section 3 of this
notice only apply if a taxpayer elects under
§ 45Q(b)(3) to apply the dollar amounts
applicable under § 45Q(a)(1) or (2) in lieu
of the dollar amounts applicable under §
45Q(a)(3) or (4).
Under § 45Q(f)(7), for taxable years
beginning in a calendar year after 2009,
the dollar amounts contained in § 45Q(a)
(1) and (2) must be adjusted for inflation
by multiplying such dollar amount by the
inflation adjustment factor for such calen-
dar year determined under § 43(b)(3)(B),
determined by substituting “2008” for
“1990.”
Section 43(b)(3)(B) defines the term
“inflation adjustment factor” as, with
respect to any calendar year, a fraction the
numerator of which is the GNP implicit
price deflator for the preceding calendar
year and the denominator of which is the
GNP implicit price deflator for 1990. For
purposes of § 45Q(f)(7), for the 2025 cal-
endar year, the inflation adjustment factor
is a fraction the numerator of which is
the GNP implicit price deflator for 2025
(128.888) and the denominator of which
is the GNP implicit price deflator for 2008
(88.046).
SECTION 3. INFLATION
ADJUSTMENT FACTOR
The inflation adjustment factor for
calendar year 2026 is 1.4639. The § 45Q
credit for calendar year 2026 is $29.28 per
metric ton of qualified carbon oxide under
§ 45Q(a)(1) and $14.64 per metric ton of
qualified carbon oxide under § 45Q(a)(2).
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is
the Office of Associate Chief Counsel
(Energy, Credits, and Excise). For fur-
ther information regarding this notice
contact (202) 317-6853 (not a toll-free
number).
1
Unless otherwise specified, all “section” references will be to the Internal Revenue Code, as amended, or the Income Tax Regulations.

May 26, 2026 1538 Bulletin No. 2026–22
2025 Section 45K(d)(2)(C)
Reference Price
Notice 2026-30
SECTION 1. PURPOSE
This notice publishes the reference
price under § 45K(d)(2)(C) of the Inter-
nal Revenue Code for calendar year
2025.
1
The credit period for the noncon-
ventional source production credit under
§ 45K ended on December 31, 2013, for
facilities producing coke or coke gas
(other than from petroleum-based prod-
ucts). However, the reference price con-
tinues to apply in determining the amount
of the enhanced oil recovery credit under
§ 43, the marginal well production credit
for qualified crude oil production under
§ 45I, and the applicable percentage
under § 613A to be used in determining
percentage depletion in the case of oil
and natural gas produced from marginal
properties.
SECTION 2. BACKGROUND
Section 45K(d)(2)(C) provides that the
term “reference price” means, with respect
to a calendar year, the Secretary’s estimate
of the annual average wellhead price per
barrel for all domestic crude oil the price
of which is not subject to regulation by the
United States.
Section 43(a) provides that, for pur-
poses of § 38, the enhanced oil recovery
credit for any taxable year is an amount
equal to 15 percent of the taxpayer’s qual-
ified enhanced oil recovery costs for such
taxable year.
Section 43(b)(1) provides that the
amount of enhanced oil recovery credit
for any taxable year shall be reduced by
an amount which bears the same ratio to
the amount of such credit (determined
without regard to this paragraph) as -
(A) the amount by which the reference
price for the calendar year preceding the
calendar year in which the taxable year
begins exceeds $28, bears to (B) $6.
Section 43(b)(2) provides that the term
“reference price” means, with respect
to any calendar year, the reference price
determined for such calendar year under
§ 45K(d)(2)(C).
Section 45I(a) provides that, for pur-
poses of § 38, the marginal well pro-
duction credit for any taxable year is an
amount equal to the product of the credit
amount and the qualified crude oil pro-
duction and the qualified natural gas pro-
duction which is attributable to the tax-
payer.
Section 45I(b)(1) provides that for
crude oil production, the amount of the
marginal well production credit is $3 per
barrel of qualified crude oil production.
Section 45I(b)(2) provides that the
$3 amount under § 45I(b)(1) shall be
reduced (but not below zero) by an
amount which bears the same ratio to
such amount (determined without regard
to this paragraph) as – (i) the excess (if
any) of the applicable reference price
over $15, bears to (ii) $3. The applica-
ble reference price for a taxable year is
the reference price of the calendar year
preceding the calendar year in which the
taxable year begins.
Section 45I(b)(2)(C) provides that for
qualified crude oil production the term
“reference price” means, with respect
to any calendar year, the reference price
determined under § 45K(d)(2)(C).
Section 613A(c)(6)(A) provides, in
general, that the allowance for depletion
under § 611 shall be computed in accor-
dance with § 613 with respect to - (i) so
much of the taxpayer’s average daily mar-
ginal production of domestic crude oil as
does not exceed the taxpayer’s depletable
oil quantity (determined without regard
to paragraph (3)(A)(ii)), and (ii) so much
of the taxpayer’s average daily marginal
production of domestic natural gas as
does not exceed the taxpayer’s depletable
natural gas quantity (determined without
regard to paragraph (3)(A)(ii)), and the
applicable percentage shall be deemed to
be specified in subsection (b) of § 613 for
purposes of subsection (a) of that section.
Section 613A(c)(6)(C) provides that
the term “applicable percentage” means
the percentage (not greater than 25 per-
cent) equal to the sum of - (i) 15 percent,
plus (ii) 1 percentage point for each whole
dollar by which $20 exceeds the refer-
ence price for crude oil for the calendar
year preceding the calendar year in which
the taxable year begins. For purposes of
this paragraph, the term “reference price”
means, with respect to any calendar year,
the reference price determined for such
calendar year under § 45K(d)(2)(C).
SECTION 3. REFERENCE PRICE
The reference price under § 45K(d)(2)
(C) for calendar year 2025 is $63.40.
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is
the Office of Associate Chief Counsel
(Energy, Credits, and Excise). For further
information regarding this notice, con-
tact (202) 317-6853 (not a toll-free num-
ber).
26 CFR 601.201: Rulings and determination letters.
Rev. Proc. 2026-21
SECTION 1. PURPOSE
This revenue procedure describes a
program for letter rulings with respect to
certain issues solely under the jurisdiction
of the Associate Chief Counsel (Corpo-
rate). This program does not diminish the
availability of letter rulings under existing
programs.
SECTION 2. CHANGES
This revenue procedure modifies and
amplifies Rev. Proc. 2026-1, 2026-1
I.R.B. 1, which explains how the Inter-
nal Revenue Service (Service) provides
advice to taxpayers on issues under the
jurisdiction of the Associate Chief Coun-
sel (Corporate). This revenue procedure
also modifies and amplifies Rev. Proc.
2026-3, 2026-1 I.R.B. 143, which sets
1
Unless otherwise specified, all “section” references will be to the Internal Revenue Code, as amended, or the Income Tax Regulations.

Bulletin No. 2026–22 1539 May 26, 2026
forth the areas of the Internal Revenue
Code (Code)
1
under the jurisdiction of
the Associate Chief Counsel (Corporate)
relating to issues on which the Service
will not issue letter rulings.
SECTION 3. BACKGROUND
.01 Prior Ruling Policy. As described
in this section 3.01, the Service has taken
various positions over time on issuing let-
ter rulings on only part of an integrated
transaction.
(1) Rev. Proc. 2001-3. Rev. Proc. 2001-
3, 2001-1 I.R.B. 111, modified by Ann.
2001-25, 2001-11 I.R.B. 895, provided
that the Service would not rule on whether
a transaction qualifies under § 332, 351,
368(a)(1)(A), (B), (C), (E) or (F), or 1036,
and whether various consequences (such
as nonrecognition and basis) result from
the application of that section, unless the
Service determined that there was a signif-
icant issue that must be resolved in order
to decide those matters. In that case, the
Service would rule on the entire transac-
tion and not just on the significant issue.
See section 3.01(29) of Rev. Proc. 2001-3.
(2) Rev. Proc. 2009-25. Rev. Proc.
2009-25, 2009-24 I.R.B. 1088, announced
a pilot program for letter rulings on issues
arising in the context of distributions to
which § 355 applies (§ 355 distributions).
Under this program, a taxpayer could
request a letter ruling on part of a larger
transaction or on a particular issue under a
Code section that a transaction presented.
In turn, the Service would issue a letter
ruling on the particular issue raised in the
letter ruling request and not on any other
issue (including, in some cases, qualifica-
tion of the distribution under § 355) or on
any other aspect of the transaction.
(3) Rev. Proc. 2013-32. Rev. Proc.
2013-32, 2013-28 I.R.B. 55, provided that
the Service no longer would rule on (i)
whether a transaction qualifies for nonrec-
ognition treatment under § 332, 351, 355,
or 1036, (ii) whether a transaction consti-
tutes a reorganization within the meaning
of § 368, or (iii) the various tax conse-
quences resulting from the application of
those Code sections. Instead, the Service
would rule only on significant issues pre-
sented in transactions described in those
Code sections (significant issue rulings).
Rev. Proc. 2013-32 further provided that
(i) the Service would not issue a letter rul-
ing with respect to an issue that is clearly
and adequately addressed by statute, reg-
ulations, decision of a court, or authority
published in the Internal Revenue Bulletin
(comfort ruling), but that (ii) except with
respect to issues under §§ 332, 351, 355,
368, and 1036 and the tax consequences
resulting from the application of those
Code sections, an Associate office may,
in its discretion, issue a comfort ruling if
the Associate office is otherwise ruling on
another issue arising in the same trans-
action. Rev. Proc. 2013-32 also provided
that the pilot program announced in Rev.
Proc. 2009-25 was discontinued.
(4) Rev. Proc. 2017-52. Rev. Proc.
2017-52, 2017-41 I.R.B. 283, provides
procedures for requesting letter rulings
regarding § 355 distributions. Rev. Proc.
2017-52 established a pilot program to
issue letter rulings that address the gen-
eral Federal income tax consequences of
a § 355 distribution. Rev. Proc. 2017-52
also provides procedures for requesting
such rulings and clarifies procedures for
requesting rulings on significant issues
presented in those transactions. Rev. Proc.
2017-52 modified and superseded a num-
ber of prior revenue procedures, including
superseding Rev. Proc. 2009-25 and Rev.
Proc. 2013-32.
(5) Rev. Proc. 2024-1 and Rev. Proc.
2024-3. Rev. Proc. 2024-1, 2024-1
I.R.B. 1, and Rev. Proc. 2024-3, 2024-1
I.R.B. 143, removed issues under §§ 332,
351, 368, and 1036 from the list of areas in
which letter rulings ordinarily would not
be issued, permitted the issuance of com-
fort rulings relating to transactions under
§§ 332, 351, 355, 368, 1036, and related
operative provisions, and ended the prac-
tice of issuing significant issue rulings,
including with respect to § 355 distribu-
tions. See sections 6.11 and 16 of Rev.
Proc. 2024-1; section 1.02 of Rev. Proc.
2024-3.
.02 Current Ruling Policy. The Service
ordinarily will not issue a letter ruling
on only part of an integrated transaction.
However, if part of an integrated trans-
action falls under an area of the Code,
including those under the jurisdiction of
the Associate Chief Counsel (Corporate),
on which the Service will not issue let-
ter rulings, the Service may issue a letter
ruling on other parts of the transaction.
Section 6.03 of Rev. Proc. 2026-1; sec-
tion 4.02(2) of Rev. Proc. 2026-3. If it is
impossible for the Service to determine the
tax consequences of an integrated transac-
tion without resolving an issue on which
the Service will not issue rulings (no-rule
issue) involving a part of the transaction
or a related transaction, the taxpayer must
state in its letter ruling request to the best
of its knowledge and belief the tax conse-
quences of the no-rule issue. The Service’s
letter ruling will state that the Service did
not consider, and no opinion is expressed
upon, that issue. In appropriate cases,
notwithstanding the taxpayer’s represen-
tation, the Service may decline to issue a
letter ruling on the integrated transaction
due to the relevance of the no-rule issue.
Section 2.03 of Rev. Proc. 2026-3.
In addition, except with respect to
issues under §§ 332, 351, 355, 368, 1036,
and related operative provisions, the Ser-
vice ordinarily will not issue comfort rul-
ings, but the Service may in its discretion
decide to issue a comfort ruling if the
Service is otherwise issuing a letter ruling
to the taxpayer on another issue arising
in the same transaction. Section 6.11 of
Rev. Proc. 2026-1; section 4.02(9) of Rev.
Proc. 2026-3.
Furthermore, the Service will not issue
letter rulings on questions that the Service
determines, in its discretion, should not
be answered in the interest of sound tax
administration, including due to resource
constraints. Section 3.02(10) of Rev. Proc.
2026-3.
A taxpayer requesting a letter ruling
solely or primarily under the jurisdiction
of the Associate Chief Counsel (Corpo-
rate) may request fast-track processing,
but not expedited handling, of that letter
ruling request. However, expedited han-
dling, but not fast-track processing, may
be available for letter ruling requests that
1
Unless otherwise provided, all "section" or "§" references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

May 26, 2026 1540 Bulletin No. 2026–22
include a closing agreement with respect
to an issue or letter ruling requests for an
extension of time for making an election
or other relief. Section 7.02(4) of Rev.
Proc. 2026-1; Rev. Proc. 2023-26, 2023-
33 I.R.B. 486.
.03 Feedback Requesting Significant
Issue Rulings. The Service has received
numerous informal comments from tax-
payers and practitioners regarding the
time required to process letter ruling
requests and the scope of those letter rul-
ing requests. Taxpayers and practitioners
have recommended that the Service rein-
state the practice of issuing significant
issue rulings. To use Service resources
more efficiently, and to increase the avail-
ability and timeliness of letter rulings, this
revenue procedure establishes a signifi-
cant issue ruling program to allow tax-
payers to request rulings on one or more
issues that—
(1) Are solely under the jurisdiction of
the Associate Chief Counsel (Corporate);
(2) Are significant (as defined in sec-
tion 4.02 of this revenue procedure); and
(3) Involve the tax consequences or
characterization of a transaction (or part
of a transaction) that is described in § 332,
351, 355, 368, or 1036.
SECTION 4. SCOPE
.01 Significant Issue Ruling Pro-
gram. Under the significant issue ruling
program described in this revenue pro-
cedure, taxpayers may request, and the
Service may issue, a ruling on part of
an integrated transaction described in
§ 332, 351, 355, 368, or 1036. In addi-
tion, taxpayers may request, and the Ser-
vice may issue, a ruling on a particular
legal issue under a section of the Code
or the Income Tax Regulations with
respect to a transaction (or part thereof)
rather than a ruling that addresses all
aspects of that section (or any other
section) with respect to the transaction
(or part thereof). For example, the Ser-
vice may issue a letter ruling address-
ing significant issues presented by the
application of § 355(e), 1.368-1(d), or
1.368-2(k), even though the ruling does
not address overall qualification of the
transaction under § 355 or 368.
In addition, the Service may rule on
the tax consequences (such as nonrec-
ognition and basis) resulting from inte-
grated transactions described in § 332,
351, 355, 368, or 1036 to the extent that
a significant issue is presented under
related Code sections that address such
tax consequences. For example, a § 351
exchange that does not present any sig-
nificant issues under § 351 may present
a significant issue regarding the appli-
cation of § 358 to the transferor in the
exchange.
This revenue procedure does not limit
the number of significant issues with
respect to a transaction that may be the
subject of a single letter ruling. However,
the Service reserves the right to rule on
any other issue related to the transaction
(including ruling adversely) if the Service
believes that doing so would be in the
interest of sound tax administration.
If the Service issues a letter ruling on a
significant issue under Rev. Proc. 2026-1
as modified and amplified by this revenue
procedure, the letter ruling will state that
no opinion is expressed as to the over-
all tax consequences of the transactions
described in the letter ruling or as to any
issue or step not specifically addressed by
the letter ruling.
.02 Significant Issue. A significant
issue is a germane and specific issue of
law, provided that a ruling on the issue
would not be a comfort ruling or the con-
clusion in such a ruling otherwise would
not be essentially free from doubt. An
issue is germane if resolution of the issue
is necessary to determine an element
of the tax treatment of the transaction.
An issue is specific if it is the narrow-
est articulation of the germane issue. A
change of circumstances arising after a
transaction ordinarily does not present
a significant issue with respect to the
transaction.
SECTION 5. PROCEDURE
.01 In General. Letter ruling requests
submitted under Rev. Proc. 2026-1 as
modified and amplified by this revenue
procedure must comply with the require-
ments set forth in Rev. Proc. 2026-1,
including the requirements of section
6.03 of Rev. Proc. 2026-1, as modified
and amplified by this revenue procedure.
All pertinent no-rule policies described in
Rev. Proc. 2026-3, as modified and ampli-
fied by this revenue procedure, will govern
requests for letter rulings made pursuant
to this revenue procedure. For example,
see section 3.01(66) of Rev. Proc. 2026-3
(no-rule policy regarding business pur-
pose under § 355).
In preparing a letter ruling request
under Rev. Proc. 2026-1 as modified
and amplified by this revenue procedure,
taxpayers should continue to consult
other applicable revenue procedures. For
example, see Rev. Proc. 2025-30, 2025-
42 I.R.B. 489 and Rev. Proc. 2017-52.
However, the letter ruling request must
include the information and representa-
tions described in such revenue proce-
dures (as applicable) only to the extent
that they relate to the significant issue.
Further, when a taxpayer is requesting a
ruling regarding a significant issue under
a section of the Code or the Income Tax
Regulations (for example, § 355(e)), the
taxpayer must provide a representation
(to the best knowledge and belief of the
taxpayer) that the transaction would oth-
erwise satisfy the requirements under
that section (for example, § 355) or, as
applicable, the relevant definitional sec-
tion (for example, § 368).
.02 Rev. Proc. 2026-1. Rev. Proc.
2026-1 is modified and amplified as fol-
lows:
(1) Section 6.03. The following text is
added after the first paragraph of section
6.03 of Rev. Proc. 2026-1:
Significant issue rulings. In addition,
the Office of Associate Chief Counsel
(Corporate) may issue a letter ruling on
part of an integrated transaction with-
out ruling on the larger transaction if the
requested ruling would address one or
more issues that: (1) are solely under the
jurisdiction of the Associate Chief Coun-
sel (Corporate); (2) are significant; and
(3) involve the tax consequences or char-
acterization of a transaction (or part of
a transaction) that is described in § 332,
351, 355, 368, or 1036. The Service also
may rule on a particular legal issue under a
section of the Code or related regulations
without ruling on other legal issues under
that section of the Code or regulations if
the issue meets the three conditions of the
preceding sentence.
A significant issue is a germane and
specific issue of law, provided that a rul-
ing on the issue would not be a comfort

Bulletin No. 2026–22 1541 May 26, 2026
ruling or the conclusion in such a ruling
otherwise would not be essentially free
from doubt. An issue is germane if reso-
lution of the issue is necessary to deter-
mine an element of the tax treatment of
the transaction. An issue is specific if it is
the narrowest articulation of the germane
issue. A change of circumstances arising
after a transaction ordinarily does not
present a significant issue with respect to
the transaction.
Before preparing the letter ruling
request under this section 6.03, a taxpayer
should follow the procedures provided in
section 10.07(1) of this revenue procedure
for pre-submission conferences to discuss
whether the Office of the Associate Chief
Counsel (Corporate) will issue a letter
ruling under this section 6.03. The Ser-
vice reserves the right to rule on any other
aspect of the transaction (including ruling
adversely) if the Service believes doing so
is in the interest of sound tax administra-
tion.
All requests for a ruling under this sec-
tion 6.03 must contain the following:
(1) A narrative description of the trans-
action that puts the significant issue in
context;
(2) A statement identifying the issue;
(3) An analysis of the relevant law
that sets forth the authorities most closely
related to the issue, explains why these
authorities do not resolve the issue, and
explains why the issue is significant;
(4) Applicable information and repre-
sentations from relevant revenue proce-
dures with respect to the significant issue
(see Appendix F of this revenue proce-
dure) and as otherwise may be required
by the Office of Associate Chief Counsel
(Corporate) depending on the facts and
circumstances;
(5) If the taxpayer is requesting a ruling
on the tax treatment of part of an integrated
transaction, a representation regarding the
relevant tax consequences of the inte-
grated transaction (to the best knowledge
and belief of the taxpayer), assuming that
the Service issues the requested ruling;
(6) The precise ruling(s) being
requested; and
(7) A statement that no rulings outside
the jurisdiction of the Associate Chief
Counsel (Corporate) are requested.
(2) Appendix C. The following text is
added after question 8 of Appendix C of
Rev. Proc. 2026-1:
See section 6.03.
.03 Rev. Proc. 2026-3. The following
text is added after the first paragraph of
section 4.02(2) of Rev. Proc. 2026-3:
Notwithstanding the prior paragraph,
in connection with transactions described
in § 332, 351, 355, 368, or 1036, the
Office of Associate Chief Counsel (Corpo-
rate) may issue a letter ruling on part of an
integrated transaction if and to the extent
that the transaction presents a signifi-
cant issue. See section 6.03 of Rev. Proc.
2026-1, 2026-1 I.R.B. 1, as modified and
amplified by Rev. Proc. 2026-21, 2026-22
I.R.B. 1538.
SECTION 6. EFFECT ON OTHER
REVENUE PROCEDURES
Rev. Proc. 2026-1 and Rev. Proc.
2026-3 are modified and amplified.
SECTION 7. EFFECTIVE DATE
The significant issue ruling pro-
gram established by this revenue proce-
dure applies to all letter ruling requests
described in section 4.01 of this revenue
procedure postmarked or, if not mailed,
received by the Service after May 5, 2026.
SECTION 8. PAPERWORK
REDUCTION ACT
The collections of information in this
revenue procedure have been reviewed
and approved by the Office of Manage-
ment and Budget (OMB) in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 1545-
1522.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
The collections of information in this
revenue procedure are in section 5. This
information is required to determine
whether a taxpayer qualifies for a letter
ruling on part of an integrated transaction
without the Service ruling on the larger
transaction. The collections of informa-
tion are required to obtain a benefit. The
likely respondents are corporations seek-
ing letter rulings. These procedures do
not change the estimated burden already
approved by OMB.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue tax law. Generally, tax returns and
tax return information are confidential, as
required by § 6103.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Jonathan H. Blake of the
Office of Associate Chief Counsel (Cor-
porate). For further information regarding
this revenue procedure, contact Mr. Blake
at (202) 317-6847 (not a toll-free call).
26 CFR 601.601: Rules and Regulations.
(Also Part I, §§ 4980H; 54.4980H)
Rev. Proc. 2026-22
SECTION 1. PURPOSE
This revenue procedure provides
indexing adjustments for the applica-
ble dollar amounts under § 4980H(c)(1)
and (b)(1) of the Internal Revenue Code.
These indexed amounts are used to cal-
culate the employer shared responsibility
payments (ESRP) under § 4980H(a) and
(b)(1), respectively.
SECTION 2. ADJUSTED ITEMS
Under § 4980H(c)(5), in the case of
any calendar year after 2014, the applica-
ble dollar amounts of $2,000 and $3,000
under § 4980H(c)(1) and (b)(1), respec-
tively, are increased by an amount equal
to the product of such dollar amount and
the premium adjustment percentage (as
defined in § 1302(c)(4) of the Patient
Protection and Affordable Care Act
1
) for
the calendar year. If the amount of any
increase is not a multiple of $10, such
1
Pub. L. 111–148, 124 Stat. 119 (2010).

May 26, 2026 1542 Bulletin No. 2026–22
increase is rounded to the next lowest
multiple of $10.
The Department of Health and Human
Services (HHS) published the premium
adjustment percentage for 2027 on Jan-
uary 29, 2026, using the most recent
National Health Expenditure Accounts
(NHEA) income and premium data that
was available at the time of publication.
For calculation of the 2027 benefit year
payment parameters, HHS used the NHEA
Projections 2024-2033, the data source
that reflected the most recent projections
available. Using the NHEA Projections
2024-2033, the premium adjustment per-
centage for 2027 is the percentage (if any)
by which the most recent NHEA projec-
tion of per enrollee premiums for private
health insurance (excluding Medigap
and property and casualty insurance) for
2026 ($8,919) exceeds the most recent
NHEA estimate of per enrollee premiums
for private health insurance (excluding
Medigap and property and casualty insur-
ance) for 2013 ($4,715) carried out to
ten significant digits. Using this formula,
the applicable premium adjustment per-
centage is 1.8916224814.
2
For calendar
year 2027, the adjusted $2,000 amount
under § 4980H(c)(1) is $3,780 ($2,000 x
1.8916224814 = $3,783.2449628 rounded
down to $3,780), and the adjusted
$3,000 amount under § 4980H(b)(1)
is $5,670 ($3,000 x 1.8916224814
= $5,674.8674442 rounded down to
$5,670).
SECTION 3. EFFECTIVE DATE
This revenue procedure is effective for
taxable years and plan years beginning
after December 31, 2026.
SECTION 4. DRAFTING
INFORMATION
The principal author of this revenue
procedure is the Office of Associate Chief
Counsel (Employee Benefits, Exempt
Organizations, and Employment Taxes).
For further information regarding this
revenue procedure, contact the Office of
Associate Chief Counsel (Employee Ben-
efits, Exempt Organizations, and Employ-
ment Taxes) at (202) 317-5500 (not a toll-
free call).
26 CFR 601.601: Rules and Regulations
(Also: Part 1, §§ 25, 143, 6a.103A-1(b)(4), 6a.103A-
2(f)(5))
Rev. Proc. 2026-23
SECTION 1. PURPOSE
This revenue procedure provides
issuers of qualified mortgage bonds, as
defined in § 143(a) of the Internal Reve-
nue Code
1
, and issuers of mortgage credit
certificates, as defined in § 25(c), with (1)
the nationwide average purchase price for
residences located in the United States,
and (2) average area purchase price safe
harbors for residences located in statis-
tical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that,
except as provided in § 103(b), gross
income does not include interest on any
State or local bond. Section 103(b)(1) pro-
vides that § 103(a) shall not apply to any
private activity bond that is not a “quali-
fied bond” within the meaning of § 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activity bond if such bond (1) is a quali-
fied mortgage bond under § 143, (2) meets
the volume cap requirements under § 146,
and (3) meets the applicable requirements
under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A) pro-
vides that the term “qualified mortgage
issue” means an issue of one or more
bonds by a State or political subdivi-
sion thereof, but only if: (i) all proceeds
of the issue (exclusive of issuance costs
and a reasonably required reserve) are to
be used to finance owner-occupied res-
idences; (ii) the issue meets the require-
ments of subsections (c), (d), (e), (f), (g),
(h), (i), and (m)(7) of § 143; (iii) the issue
does not meet the private business tests
of paragraphs (1) and (2) of § 141(b);
and (iv) with respect to amounts received
more than 10 years after the date of issu-
ance, repayments of $250,000 or more of
principal on mortgage financing provided
by the issue are used by the close of the
first semiannual period beginning after the
date the prepayment (or complete repay-
ment) is received to redeem bonds that are
part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of § 143(e) if the acquisi-
tion cost of each residence financed by
the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro-
vides that, in the case of a targeted area
residence (as defined in § 143(j)), § 143(e)
(1) shall be applied by substituting 110
percent for 90 percent.
.04 Section 143(e)(2) provides that the
term “average area purchase price” means,
with respect to any residence, the average
purchase price of single-family residences
(in the statistical area in which the res-
idence is located) that were purchased
during the most recent 12-month period
for which sufficient statistical informa-
tion is available. Under § 143(e)(3) and
(4), respectively, separate determinations
of average area purchase price are to be
made for new and existing residences,
and for two-, three-, and four-family res-
idences.
.05 Section 143(e)(2) also provides that
the determination of the average area pur-
chase price shall be made as of the date
on which the commitment to provide the
financing is made or, if earlier, the date of
the purchase of the residence.
.06 Section 143(k)(2)(A) provides
that the term “statistical area” means (i) a
metropolitan statistical area (MSA), and
(ii) any county (or the portion thereof)
that is not within an MSA. Section
143(k)(2)(C) further provides that if suf-
2
See https://www.cms.gov/files/document/2027-papi-parameters-guidance-2026-01-29.pdf.
1
Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code or the Temporary Regulations under Title II of the Omnibus Reconciliation Act of
1980 (26 CFR part 6a).

Bulletin No. 2026–22 1543 May 26, 2026
ficient recent statistical information with
respect to a county (or portion thereof)
is unavailable, the Secretary may substi-
tute another area for which there is suf-
ficient recent statistical information for
such county (or portion thereof). In the
case of any portion of a State which is not
within a county, § 143(k)(2)(D) provides
that the Secretary may designate an area
that is the equivalent of a county. Section
6a.103A-1(b)(4)(i) (issued under § 103A
of the Internal Revenue Code of 1954,
the predecessor of § 143) provides that
the term “State” includes a possession
of the United States and the District of
Columbia.
.07 Section 6a.103A-2(f)(5)(i) provides
that an issuer may rely upon the average
area purchase price safe harbors published
by the Department of the Treasury (Trea-
sury Department) for the statistical area
in which a residence is located. Section
6a.103A-2(f)(5)(i) further provides that an
issuer may use an average area purchase
price limitation different from the pub-
lished safe harbor if the issuer has more
accurate and comprehensive data for the
statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a State or
political subdivision thereof to establish
a qualified mortgage credit certificate
program. In general, a qualified mortgage
credit certificate program is a program
under which the issuing authority elects
not to issue an amount of private activity
bonds that it may otherwise issue during
the calendar year under § 146, and in its
place, issues mortgage credit certificates
to taxpayers in connection with the acqui-
sition of their principal residences. Sec-
tion 25(a)(1) provides, in general, that the
holder of a mortgage credit certificate may
claim a federal income tax credit equal to
the product of the credit rate specified
in the certificate and the interest paid or
accrued during the tax year on the remain-
ing principal of the indebtedness incurred
to acquire the residence. Section 25(c)(2)
(A)(iii)(III) generally provides that res-
idences acquired in connection with the
issuance of mortgage credit certificates
must meet the purchase price require-
ments of § 143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, § 25(c)(2)(A)
(iii)(IV) provides that holders of mortgage
credit certificates must meet the income
requirement of § 143(f). Generally, under
§§ 143(f)(1) and 25(c)(2)(A)(iii)(IV),
the income requirement is met only if all
owner-financing under a qualified mort-
gage bond and all mortgage credit certif-
icates issued under a qualified mortgage
credit certificate program are provided to
mortgagors whose family income is 115
percent or less of the applicable median
family income. Section 143(f)(5), how-
ever, generally provides for an upward
adjustment to the percentage limitation
in high housing cost areas. High housing
cost areas are defined in § 143(f)(5)(C) as
any statistical area for which the housing
cost/income ratio is greater than 1.2.
.10 Under § 143(f)(5)(D), the hous-
ing cost/income ratio with respect to any
statistical area is determined by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area
median gross income for such area bears
to the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new hous-
ing average area purchase price divided
by the new housing average purchase
price for the United States) or the exist-
ing housing price ratio (existing housing
average area purchase price divided by the
existing housing average purchase price
for the United States), whichever results
in the housing cost/income ratio being
closer to 1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2025-18, 2025-19 I.R.B. 1430.
.12 The nationwide average purchase
price was last published in section 4.02 of
Rev. Proc. 2025-18. Guidance with respect
to the United States and area median gross
income figures that are used in computing
the housing cost/income ratio described in
§ 143(f)(5) was published in Rev. Proc.
2021-19, 2021-15 I.R.B. 1008.
.13 This revenue procedure uses Fed-
eral Housing Administration (FHA) loan
limits for a given statistical area to calcu-
late the average area purchase price safe
harbor for that area. FHA sets limits on the
dollar value of loans it will insure based on
median home prices and conforming loan
limits established by the Federal Home
Loan Mortgage Corporation. In particular,
FHA sets an area’s loan limit at 95 per-
cent of the median home sales price for
the area, subject to certain floors and caps
measured against conforming loan limits.
.14 To calculate the average area pur-
chase price safe harbors in this reve-
nue procedure, the FHA loan limits are
adjusted to take into account the differ-
ences between average and median pur-
chase prices. Because FHA loan limits do
not differentiate between new and existing
residences, this revenue procedure con-
tains a single average area purchase price
safe harbor for both new and existing res-
idences in a statistical area.
.15 The average area purchase price
safe harbors listed in section 4.01 of this
revenue procedure are based on FHA
loan limits released December 11, 2025.
FHA loan limits are available for statis-
tical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar-
iana Islands, American Samoa, the Virgin
Islands, and Guam. See section 3.03 of
this revenue procedure with respect to
FHA loan limits revised after December
11, 2025.
.16 OMB Bulletin No. 23-01, dated
and effective July 21, 2023, revised the
definitions of the nation’s 935 metropol-
itan areas. The OMB bulletin no longer
includes primary MSAs.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are

May 26, 2026 1544 Bulletin No. 2026–22
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single-fam-
ily and two to four-family residences. For
each type of residence, section 4.01 of this
revenue procedure contains a single safe
harbor that may be used for both new and
existing residences. Issuers of qualified
mortgage bonds and issuers of mortgage
credit certificates may rely on these safe
harbors to satisfy the requirements of
§ 143(e) and (f). Section 4.01 of this rev-
enue procedure provides safe harbors for
MSAs and for certain counties and county
equivalents. If no purchase price safe har-
bor is available for a statistical area, the
safe harbor for “ALL OTHER AREAS”
may be used for that statistical area.
.02 If a residence is in an MSA, the safe
harbor applicable to it is the limitation of
that MSA. If an MSA falls in more than
one state, the MSA is listed in section 4.01
of this revenue procedure under each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Decem-
ber 11, 2025, an issuer of qualified mort-
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for that
statistical area to compute (as provided in
the next sentence) a revised average area
purchase price safe harbor for the statisti-
cal area provided that the issuer maintains
records evidencing the revised FHA loan
limit. The revised average area purchase
price safe harbor for that statistical area
is computed by dividing the revised FHA
loan limit by 0.860.
.04 If, pursuant to § 6a.103A-2(f)(5)(i),
an issuer uses more accurate and compre-
hensive data to determine the average area
purchase price for a statistical area, the
issuer must make separate average area
purchase price determinations for new
and existing residences. Moreover, when
computing the average area purchase
price for a statistical area that is an MSA,
as defined in OMB Bulletin No. 23-01, the
issuer must make the computation for the
entire applicable MSA. When computing
the average area purchase price for a sta-
tistical area that is not an MSA, the issuer
must make the computation for the entire
statistical area and may not combine sta-
tistical areas. Thus, for example, the issuer
may not combine two or more counties.
.05 If an issuer receives a ruling permit-
ting it to rely on an average area purchase
price limitation that is higher than the
applicable safe harbor in this revenue pro-
cedure, the issuer may rely on that higher
limitation for the purpose of satisfying the
requirements of § 143(e) and (f) for bonds
sold, and mortgage credit certificates
issued, not more than 30 months follow-
ing the termination date of the 12-month
period used by the issuer to compute the
limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue pro-
cedure sets forth a single nationwide
average purchase price for purposes of
computing the housing cost/income ratio
under § 143(f)(5).
.07 Issuers must use the nationwide
average purchase price set forth in sec-
tion 4.02 of this revenue procedure when
computing the housing cost/income ratio
under § 143(f)(5) regardless of whether
they are relying on the average area pur-
chase price safe harbors contained in this
revenue procedure or using more accu-
rate and comprehensive data to determine
average area purchase prices for new and
existing residences for a statistical area
that are different from the published safe
harbors in this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2025-18, the issuer
must use the nationwide average purchase
price set forth in section 4.02 of Rev. Proc.
2025-18 in computing the housing cost/
income ratio under § 143(f)(5). Likewise,
if, pursuant to section 6.04 of this revenue
procedure, an issuer relies on the nation-
wide average purchase price published in
Rev. Proc. 2025-18, the issuer must use
the average area purchase price safe har-
bors set forth in section 4.01 of Rev. Proc.
2025-18 in computing the housing cost/
income ratio under § 143(f)(5).
SECTION 4. AVERAGE AREA
AND NATIONWIDE AVERAGE
PURCHASE PRICES
.01 Average area purchase prices for
single-family and two to four-family res-
idences in MSAs, and for certain coun-
ties and county equivalents are set forth
below. The safe harbor for “ALL OTHER
AREAS” (found at the end of the table
below) may be used for a statistical area
that is not listed below.
2026 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
ALEUTIANS WESTAK$680,510$871,171$1,053,055$1,308,704
JUNEAU CITY ANDAK$693,879$888,261$1,073,748$1,334,396
KODIAK ISLAND BAK$629,705$806,125$974,407$1,210,990
SITKA CITY ANDAK$681,847$872,857$1,055,089$1,311,261
COCONINO COUNTYAZ$708,586$907,094$1,096,477$1,362,705
MARICOPA COUNTYAZ$648,423$830,074$1,003,413$1,246,971
PINAL COUNTYAZ$648,423$830,074$1,003,413$1,246,971
ALAMEDA COUNTYCA$1,452,194$1,859,383$2,247,478$2,793,217
ALPINE COUNTYCA$855,651$1,095,372$1,324,049$1,645,500
CONTRA COSTA COCA$1,452,194$1,859,383$2,247,478$2,793,217

Bulletin No. 2026–22 1545 May 26, 2026
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
EL DORADO COUNTCA$889,074$1,138,155$1,375,784$1,709,790
LOS ANGELES COUCA$1,452,194$1,859,383$2,247,478$2,793,217
MARIN COUNTYCA$1,452,194$1,859,383$2,247,478$2,793,217
MENDOCINO COUNTCA$635,053$812,984$982,719$1,221,278
MONO COUNTYCA$902,444$1,155,303$1,396,477$1,735,482
MONTEREY COUNTYCA$1,156,465$1,480,473$1,789,600$2,223,994
NAPA COUNTYCA$1,183,204$1,514,711$1,830,929$2,275,438
NEVADA COUNTYCA$755,379$967,025$1,168,905$1,452,688
ORANGE COUNTYCA$1,452,194$1,859,383$2,247,478$2,793,217
PLACER COUNTYCA$889,074$1,138,155$1,375,784$1,709,790
RIVERSIDE COUNTCA$802,172$1,026,897$1,241,333$1,542,670
SACRAMENTO COUNCA$889,074$1,138,155$1,375,784$1,709,790
SAN BENITO COUNCA$1,452,194$1,859,383$2,247,478$2,793,217
SAN BERNARDINOCA$802,172$1,026,897$1,241,333$1,542,670
SAN DIEGO COUNTCA$1,283,476$1,643,116$1,986,132$2,468,250
SAN FRANCISCO CCA$1,452,194$1,859,383$2,247,478$2,793,217
SAN JOAQUIN COUCA$788,803$1,009,807$1,220,639$1,516,978
SAN LUIS OBISPOCA$1,163,150$1,489,076$1,799,947$2,236,898
SAN MATEO COUNTCA$1,452,194$1,859,383$2,247,478$2,793,217
SANTA BARBARA CCA$1,094,965$1,401,767$1,694,386$2,105,761
SANTA CLARA COUCA$1,452,194$1,859,383$2,247,478$2,793,217
SANTA CRUZ COUNCA
$1,452,194$1,859,383$2,247,478$2,793,217
SOLANO COUNTYCA$796,825$1,020,096$1,233,020$1,532,382
SONOMA COUNTYCA$1,042,824$1,335,036$1,613,703$2,005,489
STANISLAUS COUNCA$633,716$811,240$980,627$1,218,721
VENTURA COUNTYCA$1,203,259$1,540,403$1,861,970$2,314,035
YOLO COUNTYCA$889,074$1,138,155$1,375,784$1,709,790
ADAMS COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
ARAPAHOE COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
BOULDER COUNTYCO$1,022,770$1,309,343$1,582,663$1,966,892
BROOMFIELD COUNCO$1,002,715$1,283,650$1,551,680$1,928,353
CHAFFEE COUNTYCO$828,911$1,061,135$1,282,720$1,594,056
CLEAR CREEK COUCO$1,002,715$1,283,650$1,551,680$1,928,353
DENVER COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
DOUGLAS COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
EAGLE COUNTYCO$1,452,194$1,859,383$2,247,478$2,793,217
EL PASO COUNTYCO$629,705$806,125$974,407$1,210,990
ELBERT COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
GARFIELD COUNTYCO$1,452,194$1,859,383$2,247,478$2,793,217
GILPIN COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
GRAND COUNTYCO$1,026,781$1,314,458$1,588,883$1,974,623
GUNNISON COUNTYCO$869,020$1,112,520$1,344,743$1,671,192
HINSDALE COUNTYCO$655,107$838,677$1,013,760$1,259,818
JEFFERSON COUNTCO$1,002,715$1,283,650
$1,551,680$1,928,353

May 26, 2026 1546 Bulletin No. 2026–22
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
LA PLATA COUNTYCO$869,020$1,112,520$1,344,743$1,671,192
LAKE COUNTYCO$1,270,106$1,625,969$1,965,439$2,442,557
LARIMER COUNTYCO$737,999$944,761$1,141,991$1,419,264
MOFFAT COUNTYCO$1,266,095$1,620,853$1,959,219$2,434,826
OURAY COUNTYCO$873,031$1,117,635$1,350,963$1,678,924
PARK COUNTYCO$1,002,715$1,283,650$1,551,680$1,928,353
PITKIN COUNTYCO$1,452,194$1,859,383$2,247,478$2,793,217
ROUTT COUNTYCO$1,266,095$1,620,853$1,959,219$2,434,826
SAN MIGUEL COUNCO$1,215,291$1,555,808$1,880,629$2,337,170
SUMMIT COUNTYCO$1,270,106$1,625,969$1,965,439$2,442,557
TELLER COUNTYCO$629,705$806,125$974,407$1,210,990
WELD COUNTYCO$668,477$855,767$1,034,454$1,285,568
GREATER BRIDGEPCT$1,136,411$1,454,838$1,758,559$2,185,455
WESTERN CONNECTCT$1,136,411$1,454,838$1,758,559$2,185,455
DISTRICT OF COLDC$1,452,194$1,859,383$2,247,478$2,793,217
NEW CASTLE COUNDE$732,651$937,902$1,133,737$1,408,975
BAKER COUNTYFL$675,162$864,312$1,044,800$1,298,415
BROWARD COUNTYFL$775,433$992,717$1,199,945$1,491,227
CLAY COUNTYFL$675,162$864,312$1,044,800$1,298,415
COLLIER COUNTYFL$889,074$1,138,155$1,375,784$1,709,790
DUVAL COUNTYFL$675,162$864,312$1,044,800$1,298,415
MANATEE COUNTYFL
$636,390$814,670$984,754$1,223,836
MARTIN COUNTYFL$701,901$898,549$1,086,130$1,349,800
MIAMI-DADE COUNFL$775,433$992,717$1,199,945$1,491,227
MONROE COUNTYFL$1,151,117$1,473,672$1,781,288$2,213,705
NASSAU COUNTYFL$675,162$864,312$1,044,800$1,298,415
OKALOOSA COUNTYFL$701,901$898,549$1,086,130$1,349,800
PALM BEACH COUNFL$775,433$992,717$1,199,945$1,491,227
SARASOTA COUNTYFL$636,390$814,670$984,754$1,223,836
ST. JOHNS COUNTFL$675,162$864,312$1,044,800$1,298,415
ST. LUCIE COUNTFL$701,901$898,549$1,086,130$1,349,800
WALTON COUNTYFL$701,901$898,549$1,086,130$1,349,800
BARROW COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
BARTOW COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
BUTTS COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
CARROLL COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
CHEROKEE COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
CLARKE COUNTYGA$716,607$917,383$1,108,916$1,378,109
CLAYTON COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
COBB COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
COWETA COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
DAWSON COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
DEKALB COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
DOUGLAS COUNTYGA$835,596$1,069,738
$1,293,067$1,606,961

Bulletin No. 2026–22 1547 May 26 2026
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
FAYETTE COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
FORSYTH COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
FULTON COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
GREENE COUNTYGA$742,009$949,877$1,148,211$1,426,937
GWINNETT COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
HARALSON COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
HEARD COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
HENRY COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
JASPER COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
LUMPKIN COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
MADISON COUNTYGA$716,607$917,383$1,108,916$1,378,109
MERIWETHER COUNGA$835,596$1,069,738$1,293,067$1,606,961
MORGAN COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
NEWTON COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
OCONEE COUNTYGA$716,607$917,383$1,108,916$1,378,109
OGLETHORPE COUNGA$716,607$917,383$1,108,916$1,378,109
PAULDING COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
PICKENS COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
PIKE COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
ROCKDALE COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
SPALDING COUNTYGA$835,596$1,069,738$1,293,067$1,606,961
WALTON COUNTYGA
$835,596$1,069,738$1,293,067$1,606,961
GUAMGU$655,107$838,677$1,013,760$1,259,818
HAWAII COUNTYHI$681,847$872,857$1,055,089$1,311,261
HONOLULU COUNTYHI$962,607$1,232,323$1,489,599$1,851,216
KALAWAO COUNTYHI$1,510,758$1,934,049$2,337,867$2,905,375
KAUAI COUNTYHI$1,291,498$1,653,347$1,998,514$2,483,712
MAUI COUNTYHI$1,510,758$1,934,049$2,337,867$2,905,375
ADA COUNTYID$681,847$872,857$1,055,089$1,311,261
BLAINE COUNTYID$882,390$1,129,610$1,365,437$1,696,943
BOISE COUNTYID$681,847$872,857$1,055,089$1,311,261
CAMAS COUNTYID$882,390$1,129,610$1,365,437$1,696,943
CANYON COUNTYID$681,847$872,857$1,055,089$1,311,261
GEM COUNTYID$681,847$872,857$1,055,089$1,311,261
KOOTENAI COUNTYID$665,803$852,337$1,030,268$1,280,395
LINCOLN COUNTYID$882,390$1,129,610$1,365,437$1,696,943
OWYHEE COUNTYID$681,847$872,857$1,055,089$1,311,261
TETON COUNTYID$1,452,194$1,859,383$2,247,478$2,793,217
VALLEY COUNTYID$715,270$915,697$1,106,824$1,375,551
BARNSTABLE COUNMA$962,607$1,232,323$1,489,599$1,851,216
BRISTOL COUNTYMA$915,813$1,172,392$1,417,171$1,761,233
DUKES COUNTYMA$1,452,194$1,859,383$2,247,478$2,793,217
ESSEX COUNTYMA$1,119,030$1,432,575$1,731,646$2,152,031
MIDDLESEX COUNTMA$1,119,030$1,432,575
$1,731,646$2,152,031

May 26, 2026 1548 Bulletin No. 2026–22
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
NANTUCKET COUNTMA$1,452,194$1,859,383$2,247,478$2,793,217
NORFOLK COUNTYMA$1,119,030$1,432,575$1,731,646$2,152,031
PLYMOUTH COUNTYMA$1,119,030$1,432,575$1,731,646$2,152,031
SUFFOLK COUNTYMA$1,119,030$1,432,575$1,731,646$2,152,031
WORCESTER COUNTMA$633,716$811,240$980,627$1,218,721
ANNE ARUNDEL COMD$869,020$1,112,520$1,344,743$1,671,192
BALTIMORE CITYMD$869,020$1,112,520$1,344,743$1,671,192
BALTIMORE COUNTMD$869,020$1,112,520$1,344,743$1,671,192
CARROLL COUNTYMD$869,020$1,112,520$1,344,743$1,671,192
CECIL COUNTYMD$732,651$937,902$1,133,737$1,408,975
CHARLES COUNTYMD$1,452,194$1,859,383$2,247,478$2,793,217
FREDERICK COUNTMD$1,452,194$1,859,383$2,247,478$2,793,217
HARFORD COUNTYMD$869,020$1,112,520$1,344,743$1,671,192
HOWARD COUNTYMD$869,020$1,112,520$1,344,743$1,671,192
MONTGOMERY COUNMD$1,452,194$1,859,383$2,247,478$2,793,217
PRINCE GEORGE'SMD$1,452,194$1,859,383$2,247,478$2,793,217
QUEEN ANNE'S COMD$869,020$1,112,520$1,344,743$1,671,192
CUMBERLAND COUNME$715,270$915,697$1,106,824$1,375,551
SAGADAHOC COUNTME$715,270$915,697$1,106,824$1,375,551
YORK COUNTYME$715,270$915,697$1,106,824$1,375,551
ANOKA COUNTYMN$641,738$821,529$993,066$1,234,125
CARVER COUNTYMN
$641,738$821,529$993,066$1,234,125
CHISAGO COUNTYMN$641,738$821,529$993,066$1,234,125
DAKOTA COUNTYMN$641,738$821,529$993,066$1,234,125
HENNEPIN COUNTYMN$641,738$821,529$993,066$1,234,125
ISANTI COUNTYMN$641,738$821,529$993,066$1,234,125
LE SUEUR COUNTYMN$641,738$821,529$993,066$1,234,125
MILLE LACS COUNMN$641,738$821,529$993,066$1,234,125
RAMSEY COUNTYMN$641,738$821,529$993,066$1,234,125
SCOTT COUNTYMN$641,738$821,529$993,066$1,234,125
SHERBURNE COUNTMN$641,738$821,529$993,066$1,234,125
WASHINGTON COUNMN$641,738$821,529$993,066$1,234,125
WRIGHT COUNTYMN$641,738$821,529$993,066$1,234,125
CARBON COUNTYMT$877,042$1,122,751$1,357,183$1,686,655
FLATHEAD COUNTYMT$715,270$915,697$1,106,824$1,375,551
GALLATIN COUNTYMT$835,596$1,069,738$1,293,067$1,606,961
MINERAL COUNTYMT$695,216$890,004$1,075,783$1,336,954
MISSOULA COUNTYMT$695,216$890,004$1,075,783$1,336,954
PARK COUNTYMT$655,107$838,677$1,013,760$1,259,818
RAVALLI COUNTYMT$651,097$833,504$1,007,540$1,252,145
STILLWATER COUNMT$877,042$1,122,751$1,357,183$1,686,655
YELLOWSTONE COUMT$877,042$1,122,751$1,357,183$1,686,655
CAMDEN COUNTYNC$881,053$1,127,924$1,363,402$1,694,386
CHATHAM COUNTYNC$737,999$944,761
$1,141,991$1,419,264

Bulletin No. 2026–22 1549 May 26, 2026
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
CURRITUCK COUNTNC$881,053$1,127,924$1,363,402$1,694,386
DARE COUNTYNC$835,596$1,069,738$1,293,067$1,606,961
DURHAM COUNTYNC$737,999$944,761$1,141,991$1,419,264
GATES COUNTYNC$881,053$1,127,924$1,363,402$1,694,386
ORANGE COUNTYNC$737,999$944,761$1,141,991$1,419,264
PERQUIMANS COUNNC$935,868$1,198,085$1,448,212$1,799,773
PERSON COUNTYNC$737,999$944,761$1,141,991$1,419,264
DAWSON COUNTYNE$701,901$898,549$1,086,130$1,349,800
GOSPER COUNTYNE$701,901$898,549$1,086,130$1,349,800
CARROLL COUNTYNH$635,053$812,984$982,719$1,221,278
HILLSBOROUGH CONH$685,857$878,030$1,061,309$1,318,992
ROCKINGHAM COUNNH$1,119,030$1,432,575$1,731,646$2,152,031
STRAFFORD COUNTNH$1,119,030$1,432,575$1,731,646$2,152,031
ATLANTIC COUNTYNJ$848,966$1,086,827$1,313,703$1,632,653
BERGEN COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
BURLINGTON COUNNJ$732,651$937,902$1,133,737$1,408,975
CAMDEN COUNTYNJ$732,651$937,902$1,133,737$1,408,975
CAPE MAY COUNTYNJ$848,966$1,086,827$1,313,703$1,632,653
ESSEX COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
GLOUCESTER COUNNJ$732,651$937,902$1,133,737$1,408,975
HUDSON COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
HUNTERDON COUNTNJ
$1,452,194$1,859,383$2,247,478$2,793,217
MIDDLESEX COUNTNJ$1,452,194$1,859,383$2,247,478$2,793,217
MONMOUTH COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
MORRIS COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
OCEAN COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
PASSAIC COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
SALEM COUNTYNJ$732,651$937,902$1,133,737$1,408,975
SOMERSET COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
SUSSEX COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
UNION COUNTYNJ$1,452,194$1,859,383$2,247,478$2,793,217
LOS ALAMOS COUNNM$804,846$1,030,326$1,245,460$1,547,786
SANTA FE COUNTYNM$661,792$847,222$1,024,107$1,272,664
CARSON CITYNV$668,477$855,767$1,034,454$1,285,568
DOUGLAS COUNTYNV$855,651$1,095,372$1,324,049$1,645,500
LYON COUNTYNV$742,009$949,877$1,148,211$1,426,937
STOREY COUNTYNV$742,009$949,877$1,148,211$1,426,937
WASHOE COUNTYNV$742,009$949,877$1,148,211$1,426,937
BRONX COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
KINGS COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
NASSAU COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
NEW YORK COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
PUTNAM COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
QUEENS COUNTYNY$1,452,194$1,859,383
$2,247,478$2,793,217

May 26, 2026 1550 Bulletin No. 2026–22
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
RICHMOND COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
ROCKLAND COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
SUFFOLK COUNTYNY$1,452,194$1,859,383$2,247,478$2,793,217
WESTCHESTER COUNY$1,452,194$1,859,383$2,247,478$2,793,217
DELAWARE COUNTYOH$687,194$879,716$1,063,402$1,321,550
FAIRFIELD COUNTOH$687,194$879,716$1,063,402$1,321,550
FRANKLIN COUNTYOH$687,194$879,716$1,063,402$1,321,550
HOCKING COUNTYOH$687,194$879,716$1,063,402$1,321,550
LICKING COUNTYOH$687,194$879,716$1,063,402$1,321,550
MADISON COUNTYOH$687,194$879,716$1,063,402$1,321,550
MORROW COUNTYOH$687,194$879,716$1,063,402$1,321,550
PERRY COUNTYOH$687,194$879,716$1,063,402$1,321,550
PICKAWAY COUNTYOH$687,194$879,716$1,063,402$1,321,550
UNION COUNTYOH$687,194$879,716$1,063,402$1,321,550
BENTON COUNTYOR$715,270$915,697$1,106,824$1,375,551
CLACKAMAS COUNTOR$815,542$1,044,045$1,262,026$1,568,363
CLATSOP COUNTYOR$655,107$838,677$1,013,760$1,259,818
COLUMBIA COUNTYOR$815,542$1,044,045$1,262,026$1,568,363
CROOK COUNTYOR$835,596$1,069,738$1,293,067$1,606,961
DESCHUTES COUNTOR$835,596$1,069,738$1,293,067$1,606,961
HOOD RIVER COUNOR$886,400$1,134,783$1,371,657$1,704,616
JEFFERSON COUNTOR
$835,596$1,069,738$1,293,067$1,606,961
MULTNOMAH COUNTOR$815,542$1,044,045$1,262,026$1,568,363
WASHINGTON COUNOR$815,542$1,044,045$1,262,026$1,568,363
YAMHILL COUNTYOR$815,542$1,044,045$1,262,026$1,568,363
BUCKS COUNTYPA$732,651$937,902$1,133,737$1,408,975
CHESTER COUNTYPA$732,651$937,902$1,133,737$1,408,975
DELAWARE COUNTYPA$732,651$937,902$1,133,737$1,408,975
MONTGOMERY COUNPA$732,651$937,902$1,133,737$1,408,975
PHILADELPHIA COPA$732,651$937,902$1,133,737$1,408,975
AGUAS BUENAS MUPR$802,172$1,026,897$1,241,333$1,542,670
AIBONITO MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
BARCELONETA MUNPR$802,172$1,026,897$1,241,333$1,542,670
BARRANQUITAS MUPR$802,172$1,026,897$1,241,333$1,542,670
BAYAMON MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
CAGUAS MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
CANOVANAS MUNICPR$802,172$1,026,897$1,241,333$1,542,670
CAROLINA MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
CATANO MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
CAYEY MUNICIPIOPR$802,172$1,026,897$1,241,333$1,542,670
CEIBA MUNICIPIOPR$802,172$1,026,897$1,241,333$1,542,670
CIALES MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
CIDRA MUNICIPIOPR$802,172$1,026,897$1,241,333$1,542,670
COMERIO MUNICIPPR$802,172$1,026,897
$1,241,333$1,542,670

Bulletin No. 2026–22 1551 May 26, 2026
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
COROZAL MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
DORADO MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
FAJARDO MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
FLORIDA MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
GUAYNABO MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
GURABO MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
HUMACAO MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
JUNCOS MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
LAS PIEDRAS MUNPR$802,172$1,026,897$1,241,333$1,542,670
LOIZA MUNICIPIOPR$802,172$1,026,897$1,241,333$1,542,670
LUQUILLO MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
MANATI MUNICIPIPR$802,172$1,026,897$1,241,333$1,542,670
MAUNABO MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
MOROVIS MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
NAGUABO MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
NARANJITO MUNICPR$802,172$1,026,897$1,241,333$1,542,670
OROCOVIS MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
RIO GRANDE MUNIPR$802,172$1,026,897$1,241,333$1,542,670
SAN JUAN MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
SAN LORENZO MUNPR$802,172$1,026,897$1,241,333$1,542,670
TOA ALTA MUNICIPR$802,172$1,026,897$1,241,333$1,542,670
TOA BAJA MUNICIPR
$802,172$1,026,897$1,241,333$1,542,670
TRUJILLO ALTO MPR$802,172$1,026,897$1,241,333$1,542,670
VEGA ALTA MUNICPR$802,172$1,026,897$1,241,333$1,542,670
VEGA BAJA MUNICPR$802,172$1,026,897$1,241,333$1,542,670
YABUCOA MUNICIPPR$802,172$1,026,897$1,241,333$1,542,670
BRISTOL COUNTYRI$915,813$1,172,392$1,417,171$1,761,233
KENT COUNTYRI$915,813$1,172,392$1,417,171$1,761,233
NEWPORT COUNTYRI$915,813$1,172,392$1,417,171$1,761,233
PROVIDENCE COUNRI$915,813$1,172,392$1,417,171$1,761,233
WASHINGTON COUNRI$915,813$1,172,392$1,417,171$1,761,233
BEAUFORT COUNTYSC$742,009$949,877$1,148,211$1,426,937
BERKELEY COUNTYSC$802,172$1,026,897$1,241,333$1,542,670
CHARLESTON COUNSC$802,172$1,026,897$1,241,333$1,542,670
DORCHESTER COUNSC$802,172$1,026,897$1,241,333$1,542,670
JASPER COUNTYSC$742,009$949,877$1,148,211$1,426,937
LAWRENCE COUNTYSD$629,705$806,125$974,407$1,210,990
CANNON COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
CHEATHAM COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
DAVIDSON COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
DICKSON COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
HICKMAN COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
MACON COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
MAURY COUNTYTN$1,196,574$1,531,859
$1,851,623$2,301,130

May 26, 2026 1552 Bulletin No. 2026–22
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
ROBERTSON COUNTTN$1,196,574$1,531,859$1,851,623$2,301,130
RUTHERFORD COUNTN$1,196,574$1,531,859$1,851,623$2,301,130
SMITH COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
SUMNER COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
TROUSDALE COUNTTN$1,196,574$1,531,859$1,851,623$2,301,130
WILLIAMSON COUNTN$1,196,574$1,531,859$1,851,623$2,301,130
WILSON COUNTYTN$1,196,574$1,531,859$1,851,623$2,301,130
ATASCOSA COUNTYTX$648,423$830,074$1,003,413$1,246,971
BANDERA COUNTYTX$648,423$830,074$1,003,413$1,246,971
BASTROP COUNTYTX$664,466$850,651$1,028,234$1,277,837
BEXAR COUNTYTX$648,423$830,074$1,003,413$1,246,971
CALDWELL COUNTYTX$664,466$850,651$1,028,234$1,277,837
COLLIN COUNTYTX$655,107$838,677$1,013,760$1,259,818
COMAL COUNTYTX$648,423$830,074$1,003,413$1,246,971
DALLAS COUNTYTX$655,107$838,677$1,013,760$1,259,818
DENTON COUNTYTX$655,107$838,677$1,013,760$1,259,818
ELLIS COUNTYTX$655,107$838,677$1,013,760$1,259,818
GLASSCOCK COUNTTX$945,226$1,210,060$1,462,686$1,817,792
GUADALUPE COUNTTX$648,423$830,074$1,003,413$1,246,971
HAYS COUNTYTX$664,466$850,651$1,028,234$1,277,837
HUNT COUNTYTX$655,107$838,677$1,013,760$1,259,818
JOHNSON COUNTYTX
$655,107$838,677$1,013,760$1,259,818
KAUFMAN COUNTYTX$655,107$838,677$1,013,760$1,259,818
KENDALL COUNTYTX$648,423$830,074$1,003,413$1,246,971
MEDINA COUNTYTX$648,423$830,074$1,003,413$1,246,971
PARKER COUNTYTX$655,107$838,677$1,013,760$1,259,818
ROCKWALL COUNTYTX$655,107$838,677$1,013,760$1,259,818
TARRANT COUNTYTX$655,107$838,677$1,013,760$1,259,818
TRAVIS COUNTYTX$664,466$850,651$1,028,234$1,277,837
WILLIAMSON COUNTX$664,466$850,651$1,028,234$1,277,837
WILSON COUNTYTX$648,423$830,074$1,003,413$1,246,971
WISE COUNTYTX$655,107$838,677$1,013,760$1,259,818
DAVIS COUNTYUT$865,009$1,107,347$1,338,582$1,663,519
GRAND COUNTYUT$975,976$1,249,413$1,510,293$1,876,909
JUAB COUNTYUT$699,227$895,120$1,082,003$1,344,685
MORGAN COUNTYUT$865,009$1,107,347$1,338,582$1,663,519
RICH COUNTYUT$673,825$862,626$1,042,708$1,295,857
SALT LAKE COUNTUT$740,672$948,191$1,146,176$1,424,379
SUMMIT COUNTYUT$1,352,997$1,732,111$2,093,728$2,602,003
TOOELE COUNTYUT$740,672$948,191$1,146,176$1,424,379
UTAH COUNTYUT$699,227$895,120$1,082,003$1,344,685
WASATCH COUNTYUT$1,352,997$1,732,111$2,093,728$2,602,003
WASHINGTON COUNUT$705,912$903,665$1,092,350$1,357,531
WAYNE COUNTYUT$1,159,139$1,483,903
$1,793,727$2,229,167

Bulletin No. 2026–22 1553 May 26, 2026
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
WEBER COUNTYUT$865,009$1,107,347$1,338,582$1,663,519
ALBEMARLE COUNTVA$695,216$890,004$1,075,783$1,336,954
ALEXANDRIA CITYVA$1,452,194$1,859,383$2,247,478$2,793,217
AMELIA COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
ARLINGTON COUNTVA$1,452,194$1,859,383$2,247,478$2,793,217
CHARLES CITY COVA$822,227$1,052,590$1,272,373$1,581,210
CHARLOTTESVILLEVA$695,216$890,004$1,075,783$1,336,954
CHESAPEAKE CITYVA$881,053$1,127,924$1,363,402$1,694,386
CHESTERFIELD COVA$822,227$1,052,590$1,272,373$1,581,210
CLARKE COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
COLONIAL HEIGHTVA$822,227$1,052,590$1,272,373$1,581,210
CULPEPER COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
DINWIDDIE COUNTVA$822,227$1,052,590$1,272,373$1,581,210
FAIRFAX CITYVA$1,452,194$1,859,383$2,247,478$2,793,217
FAIRFAX COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
FALLS CHURCH CIVA$1,452,194$1,859,383$2,247,478$2,793,217
FAUQUIER COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
FLUVANNA COUNTYVA$695,216$890,004$1,075,783$1,336,954
FREDERICKSBURGVA$1,452,194$1,859,383$2,247,478$2,793,217
GLOUCESTER COUNVA$881,053$1,127,924$1,363,402$1,694,386
GOOCHLAND COUNTVA$822,227$1,052,590$1,272,373$1,581,210
GREENE COUNTYVA
$695,216$890,004$1,075,783$1,336,954
HAMPTON CITYVA$881,053$1,127,924$1,363,402$1,694,386
HANOVER COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
HENRICO COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
HOPEWELL CITYVA$822,227$1,052,590$1,272,373$1,581,210
ISLE OF WIGHT CVA$881,053$1,127,924$1,363,402$1,694,386
JAMES CITY COUNVA$881,053$1,127,924$1,363,402$1,694,386
KING AND QUEENVA$822,227$1,052,590$1,272,373$1,581,210
KING WILLIAM COVA$822,227$1,052,590$1,272,373$1,581,210
LOUDOUN COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
MANASSAS CITYVA$1,452,194$1,859,383$2,247,478$2,793,217
MANASSAS PARK CVA$1,452,194$1,859,383$2,247,478$2,793,217
MATHEWS COUNTYVA$881,053$1,127,924$1,363,402$1,694,386
NELSON COUNTYVA$695,216$890,004$1,075,783$1,336,954
NEW KENT COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
NEWPORT NEWS CIVA$881,053$1,127,924$1,363,402$1,694,386
NORFOLK CITYVA$881,053$1,127,924$1,363,402$1,694,386
PETERSBURG CITYVA$822,227$1,052,590$1,272,373$1,581,210
POQUOSON CITYVA$881,053$1,127,924$1,363,402$1,694,386
PORTSMOUTH CITYVA$881,053$1,127,924$1,363,402$1,694,386
POWHATAN COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
PRINCE GEORGE CVA$822,227$1,052,590$1,272,373$1,581,210
PRINCE WILLIAMVA$1,452,194$1,859,383
$2,247,478$2,793,217

May 26, 2026 1554 Bulletin No. 2026–22
County NameStateOne-Unit LimitTwo-Unit LimitThree-Unit LimitFour-Unit Limit
RAPPAHANNOCK COVA$1,452,194$1,859,383$2,247,478$2,793,217
RICHMOND CITYVA$822,227$1,052,590$1,272,373$1,581,210
SPOTSYLVANIA COVA$1,452,194$1,859,383$2,247,478$2,793,217
STAFFORD COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
SUFFOLK CITYVA$881,053$1,127,924$1,363,402$1,694,386
SURRY COUNTYVA$881,053$1,127,924$1,363,402$1,694,386
SUSSEX COUNTYVA$822,227$1,052,590$1,272,373$1,581,210
VIRGINIA BEACHVA$881,053$1,127,924$1,363,402$1,694,386
WARREN COUNTYVA$1,452,194$1,859,383$2,247,478$2,793,217
WILLIAMSBURG CIVA$881,053$1,127,924$1,363,402$1,694,386
YORK COUNTYVA$881,053$1,127,924$1,363,402$1,694,386
ST. JOHN ISLANDVI$1,303,530$1,668,751$2,017,173$2,506,847
ST. THOMAS ISLAVI$787,466$1,008,121$1,218,546$1,514,362
CHITTENDEN COUNVT$668,477$855,767$1,034,454$1,285,568
FRANKLIN COUNTYVT$668,477$855,767$1,034,454$1,285,568
GRAND ISLE COUNVT$668,477$855,767$1,034,454$1,285,568
CHELAN COUNTYWA$681,847$872,857$1,055,089$1,311,261
CLARK COUNTYWA$815,542$1,044,045$1,262,026$1,568,363
DOUGLAS COUNTYWA$681,847$872,857$1,055,089$1,311,261
ISLAND COUNTYWA$780,781$999,518$1,208,199$1,501,516
KING COUNTYWA$1,236,682$1,583,186$1,913,704$2,378,267
KITSAP COUNTYWA
$716,607$917,383$1,108,916$1,378,109
PIERCE COUNTYWA$1,236,682$1,583,186$1,913,704$2,378,267
SAN JUAN COUNTYWA$791,477$1,013,237$1,224,766$1,522,093
SKAGIT COUNTYWA$721,955$924,242$1,117,170$1,388,398
SKAMANIA COUNTYWA$815,542$1,044,045$1,262,026$1,568,363
SNOHOMISH COUNTWA$1,236,682$1,583,186$1,913,704$2,378,267
THURSTON COUNTYWA$681,847$872,857$1,055,089$1,311,261
WHATCOM COUNTYWA$772,759$989,288$1,195,818$1,486,112
WHITMAN COUNTYWA$673,825$862,626$1,042,708$1,295,857
PIERCE COUNTYWI$641,738$821,529$993,066$1,234,125
ST. CROIX COUNTWI$641,738$821,529$993,066$1,234,125
JEFFERSON COUNTWV$1,452,194$1,859,383$2,247,478$2,793,217
TETON COUNTYWY$1,452,194$1,859,383$2,247,478$2,793,217
UINTA COUNTYWY$673,825$862,626$1,042,708$1,295,857
All other areas – 2,794 counties
(floor):
$629,283$805,718$973,884$1,210,379

Bulletin No. 2026–22 1555 May 26, 2026
.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$553,900.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2025-18 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area pur-
chase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if
the purchase precedes the commitment)
for residences that are purchased, in the
period that begins on May 6, 2026, and
ends on the date as of which the safe har-
bors contained in section 4.01 of this rev-
enue procedure are rendered obsolete by a
new revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc. 2025-
18, with respect to bonds sold, or for mort-
gage credit certificates issued with respect
to bond authority exchanged, before June
5, 2026, if the commitments to provide
financing or issue mortgage credit certif-
icates are made on or before July 6, 2026.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in this
revenue procedure for commitments to
provide financing or issue mortgage credit
certificates that are made, or (if the pur-
chase precedes the commitment) for res-
idences that are purchased, in the period
that begins on May 6, 2026 and ends on
the date when the nationwide average pur-
chase price limitation is rendered obsolete
by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2025-18 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before June 5, 2026, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
July 6, 2026.
SECTION 7. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 1545-
1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a col-
lection of information requirement in sec-
tion 3.03. The purpose of the collection
of information is to verify the applicable
FHA loan limit that issuers of qualified
mortgage bonds and qualified mortgage
certificates have used to calculate the
average area purchase price for a given
MSA for purposes of §§ 143(e) and 25(c).
The collection of information is required
to obtain the benefit of using revisions to
FHA loan limits to determine average area
purchase prices. The likely respondents
are state and local governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per
respondent and/or recordkeeper: 15 min-
utes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. 6103.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Brian Choi of the Office of
Associate Chief Counsel (Financial Insti-
tutions & Products). For further infor-
mation regarding this revenue procedure
contact Mr. Choi on (202) 317-3154 (not a
toll-free number).

Bulletin No. 2026–22 i May 26, 2026
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.
—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

May 26, 2026 ii Bulletin No. 2026–22
Numerical Finding List
1
Bulletin 2026–22
Announcements:
2026-1, 2026-04 I.R.B. 402
2026-2, 2026-05 I.R.B. 447
2026-3, 2026-06 I.R.B. 518
2026-4, 2026-06 I.R.B. 533
2026-5, 2026-07 I.R.B. 540
2026-6, 2026-10 I.R.B. 634
2026-7, 2026-11 I.R.B. 697
2026-8, 2026-16 I.R.B. 813
2026-9, 2026-18 I.R.B. 881
Notices:
2026-2, 2026-02 I.R.B. 304
2026-3, 2026-02 I.R.B. 307
2026-5, 2026-02 I.R.B. 309
2026-6, 2026-02 I.R.B. 313
2026-1, 2026-04 I.R.B. 365
2026-8, 2026-04 I.R.B. 368
2026-10, 2026-04 I.R.B. 378
2026-11, 2026-06 I.R.B. 491
2026-12, 2026-06 I.R.B. 496
2026-13, 2026-06 I.R.B. 499
2026-9, 2026-07 I.R.B. 534
2026-7, 2026-11 I.R.B. 637
2026-14, 2026-11 I.R.B. 654
2026-15, 2026-11 I.R.B. 658
2026-16, 2026-11 I.R.B. 685
2026-17, 2026-12 I.R.B. 698
2026-4, 2026-13 I.R.B. 726
2026-19, 2026-15 I.R.B. 797
2026-20, 2026-15 I.R.B. 800
2026-22, 2026-15 I.R.B. 802
2026-23, 2026-15 I.R.B. 804
2026-24, 2026-17 I.R.B. 835
2026-25, 2026-17 I.R.B. 836
2026-26, 2026-18 I.R.B. 878
2026-27, 2026-21 I.R.B. 1502
2026-29, 2026-22 I.R.B. 1537
2026-30, 2026-22 I.R.B. 1538
Proposed Regulations:
REG-101952-24, 2026-03 I.R.B. 345
REG-110519-25, 2026-03 I.R.B. 353
REG-132251-11; REG-134219-08,
2026-03 I.R.B. 358
REG-103430-24, 2026-05 I.R.B. 447
REG-112829-25, 2026-05 I.R.B. 452
REG-113515-25, 2026-05 I.R.B. 455
REG-121244-23, 2026-09 I.R.B. 579
REG-105064-25, 2026-13 I.R.B. 735
REG-108921-25, 2026-13 I.R.B. 756
REG-117002-25, 2026-13 I.R.B. 761
REG-117270-25, 2026-13 I.R.B. 772
Proposed Regulations:—Continued
REG-117298-21, 2026-14 I.R.B. 784
REG-114499-25, 2026-18 I.R.B. 883
REG-113229-25, 2026-19 I.R.B. 900
REG-108706-25, 2026-21 I.R.B. 1508
REG-119294-25, 2026-21 I.R.B. 1509
Revenue Procedures:
2026-1, 2026-01 I.R.B. 1
2026-2, 2026-01 I.R.B. 119
2026-3, 2026-01 I.R.B. 143
2026-4, 2026-01 I.R.B. 160
2026-5, 2026-01 I.R.B. 258
2026-6, 2026-02 I.R.B. 314
2026-7, 2026-02 I.R.B. 316
2026-8, 2026-04 I.R.B. 380
2026-9, 2026-04 I.R.B. 393
2026-10, 2026-04 I.R.B. 394
2026-12, 2026-07 I.R.B. 535
2026-13, 2026-09 I.R.B. 563
2026-11, 2026-12 I.R.B. 707
2026-15, 2026-13 I.R.B. 729
2026-16, 2026-13 I.R.B. 733
2026-17, 2026-15 I.R.B. 805
2026-19, 2026-19 I.R.B. 899
2026-14, 2026-20 I.R.B. 910
2026-21, 2026-22 I.R.B. 1538
2026-22, 2026-22 I.R.B. 1541
2026-23, 2026-22 I.R.B. 1542
Revenue Rulings:
2026-1, 2026-02 I.R.B. 299
2026-2, 2026-03 I.R.B. 342
2026-3, 2026-06 I.R.B. 485
2026-4, 2026-06 I.R.B. 487
2026-5, 2026-08 I.R.B. 542
2026-6, 2026-11 I.R.B. 635
2026-7, 2026-15 I.R.B. 791
2026-8, 2026-16 I.R.B. 812
2026-9, 2026-19 I.R.B. 897
2026-10, 2026-22 I.R.B. 1515
Treasury Decisions:
10042, 2026-03 I.R.B. 320
10041, 2026-04 I.R.B. 360
10039, 2026-05 I.R.B. 403
10040, 2026-05 I.R.B. 416
10043, 2026-15 I.R.B. 793
10044, 2026-18 I.R.B. 840
10045, 2026-21 I.R.B. 1491
10047, 2026-21 I.R.B. 1494
10046, 2026-22 I.R.B. 1512
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin
2024–52, dated December 22, 2024.

Bulletin No. 2026–22 iii May 26, 2026
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2026–22
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin
2024–52, dated December 22, 2024.

Internal Revenue Service
Washington, DC 20224
Official Business
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