IRS Bulletin No. 2026–35: Key Updates on Enhanced Oil Recovery Credit, Estate Tax Special Use Valuation, Saver’s Match Contributions, and Rollover Procedures

IRS Bulletin No. 2026–35: A Comprehensive Overview of Key Tax Updates

The Internal Revenue Bulletin No. 2026–35, published on August 24, 2026, introduces a series of consequential updates spanning energy incentives, estate tax valuation, retirement savings, and administrative procedures. These changes reflect broader political and economic currents, including the lingering effects of the SECURE 2.0 Act of 2022, persistent inflationary pressures, and the evolving regulatory landscape for retirement planning and estate administration. The Bulletin’s four focal points—inflation-adjusted Enhanced Oil Recovery (EOR) credit phase-outs under Section 43, revised interest rates for estate tax special use valuations under Section 2032A, the impending implementation of Saver’s Match contributions under Section 6433, and streamlined rollover procedures under Section 324 of SECURE 2.0—signal a deliberate shift toward recalibrating incentives in response to market conditions while advancing administrative efficiency.

The EOR credit adjustments, tied to the GNP Implicit Price Deflator, underscore the IRS’s responsiveness to macroeconomic volatility, particularly the sustained rise in oil prices that triggered phase-outs for 2026. Meanwhile, the updated interest rates for special use valuations of farm real property under Section 2032A arrive amid a high-interest-rate environment, diminishing the tax benefits of this longstanding estate planning tool. The Saver’s Match, a hallmark of SECURE 2.0, represents a paradigm shift in retirement savings incentives by converting a non-refundable credit into a direct government contribution, though its full implementation remains years away. Finally, the IRS’s push to simplify rollover procedures through new guidance and sample forms aligns with broader efforts to reduce administrative burdens and enhance compliance, even as it introduces new procedural complexities.

Each of these developments will be examined in depth in the following sections, where the legal mechanics, contextual underpinnings, and practical implications for practitioners will be dissected. The Bulletin’s issuance arrives at a juncture where political debates over energy policy, retirement security, and estate tax fairness continue to shape the tax code’s trajectory, making these updates not merely technical adjustments but strategic maneuvers in a broader fiscal and regulatory chess game.

Enhanced Oil Recovery Credit: Inflation Adjustments and Phase-Out for 2026

The IRS’s Notice 2026-46, published in IRB 2026–35, delivers a critical inflation adjustment for the Section 43 Enhanced Oil Recovery (EOR) Credit, a non-refundable tax credit designed to incentivize tertiary recovery methods in mature oil fields. The notice confirms that the credit, which equals 15% of qualified EOR costs, will be partially phased out for taxable years beginning in 2026 due to sustained high oil prices. This adjustment reflects the ongoing tension between energy policy incentives and market realities, where rising crude prices erode the need for government subsidies. The phase-out mechanism, tied to the GNP Implicit Price Deflator (IPD) and the reference price for domestic crude oil, demonstrates how tax policy adapts—or fails to adapt—to volatile commodity markets. For practitioners, this notice underscores the importance of monitoring both inflation metrics and oil price benchmarks to determine credit eligibility year over year.

The EOR credit, codified in Section 43 of the Internal Revenue Code (26 U.S. Code § 43), was enacted in 1990 as part of the Omnibus Budget Reconciliation Act to stimulate investment in enhanced oil recovery technologies, such as CO₂ injection and thermal recovery, in declining oil fields. The credit was originally intended to offset the high costs of tertiary recovery methods, which are more expensive than conventional drilling but can extend the productive life of aging wells. Over time, the credit’s phase-out mechanism—triggered when oil prices exceed inflation-adjusted thresholds—has become its defining feature, turning it into a de facto subsidy that fluctuates with global energy markets. The credit’s relevance has waxed and waned alongside oil prices, with full phase-outs occurring during periods of high crude prices, such as in 2022–2024, when West Texas Intermediate (WTI) averaged over $90 per barrel. The 2026 adjustment arrives at a moment when political debates over fossil fuel subsidies and the energy transition are intensifying, with some lawmakers advocating for the credit’s repeal while others seek to extend it as part of broader energy security measures.

The inflation adjustment factor for 2026 is calculated using the GNP Implicit Price Deflator (IPD), a broad measure of inflation published by the Bureau of Economic Analysis (BEA). The GNP IPD reflects the change in prices of all goods and services produced in the U.S. economy, including consumer goods, investment goods, government spending, and net exports. For the EOR credit, the inflation adjustment factor is a fraction where the numerator is the GNP IPD for the preceding calendar year (2025) and the denominator is the GNP IPD for 1990, the base year for the credit’s phase-out thresholds. The notice specifies that the 2025 GNP IPD is 135.0, while the 1990 GNP IPD is 60.6, yielding an inflation adjustment factor of 2.2277 (135.0 / 60.6). This factor is then applied to the base phase-out thresholds of $28 per barrel (phase-out start) and $34 per barrel (full phase-out), adjusting them to $62.38 per barrel and $75.94 per barrel, respectively. The notice provides a table (Table 1) listing the inflation-adjusted thresholds for 2026, which are critical for taxpayers determining whether their projects qualify for the credit.

The phase-out mechanism for the EOR credit is triggered when the reference price for crude oil—defined as the average annual wellhead price of domestic crude oil—exceeds the inflation-adjusted phase-out thresholds. Under Section 43(b)(1), the credit is phased out by an amount that bears the same ratio to the credit as the amount by which the reference price exceeds the inflation-adjusted $28 threshold bears to the difference between the inflation-adjusted $34 threshold and the $28 threshold. In 2026, the reference price for domestic crude oil is projected to be $75.20 per barrel, which falls between the adjusted phase-out start ($62.38) and full phase-out ($75.94) thresholds. This places the credit in a partial phase-out scenario, where the credit percentage is reduced proportionally. The notice calculates the reduced credit percentage for 2026 as 7.3%, down from the statutory 15%, reflecting the partial phase-out triggered by the reference price. Taxpayers must apply this reduced percentage to their qualified EOR costs to determine the allowable credit for the taxable year.

The implications for oil and gas industry taxpayers are significant, particularly for those operating in mature fields where tertiary recovery methods are economically marginal. The partial phase-out in 2026 means that the credit will provide only 48.7% of its original value (7.3% / 15%), reducing the incentive for investment in EOR projects. This reduction comes at a time when the industry is under pressure to decarbonize, with some companies shifting capital toward renewable energy and carbon capture projects. The EOR credit’s declining value may accelerate this shift, as taxpayers reassess the cost-effectiveness of tertiary recovery methods. For practitioners, the notice serves as a reminder to model the credit’s impact carefully, considering not only the immediate tax savings but also the long-term strategic implications for energy investments. The notice also highlights the need to track the GNP IPD and oil price benchmarks annually, as these metrics will continue to drive the credit’s availability and value.

Historically, the EOR credit has been a contentious policy tool, reflecting broader debates over fossil fuel subsidies and energy transition. Enacted in 1990, the credit was designed to extend the life of domestic oil fields and reduce reliance on foreign oil, a goal that aligned with the energy security priorities of the time. However, as oil prices have risen and fallen over the decades, the credit’s phase-out mechanism has often rendered it irrelevant during periods of high prices, such as the 2000s oil boom, and more valuable during price downturns, such as the 2010s. The credit’s relevance in the current energy market is further complicated by the push for decarbonization, with some lawmakers and environmental groups advocating for its repeal as part of broader efforts to phase out fossil fuel subsidies. The 2026 adjustment arrives at a juncture where the political and economic landscape for energy policy is rapidly evolving, with the Biden administration’s Inflation Reduction Act (IRA) of 2022 introducing new clean energy incentives that may overshadow traditional fossil fuel subsidies like the EOR credit. For practitioners, the notice underscores the importance of staying abreast of both tax policy and energy market trends to advise clients effectively.

Estate Tax Special Use Valuation: Updated Interest Rates for Farms in 2026

The Internal Revenue Service’s Rev. Rul. 2026-14, published in IRB 2026-35, provides the 2026 interest rates used to compute the special use value of farm real property under Section 2032A of the Internal Revenue Code. These rates are derived from the Federal mid-term rate (FMR) and are essential for estate planners and farm owners seeking to reduce estate tax liability through the special use valuation election. The ruling arrives at a time when agricultural land values are under pressure from rising interest rates and inflation, making the updated rates particularly consequential for estate planning strategies.

The Purpose of Section 2032A and Its Role in Estate Tax Valuations for Farms

Section 2032A of the Internal Revenue Code allows the executor of an estate to elect to value certain farm real property based on its actual use as a farm rather than its highest and best use, which could be significantly higher. This provision is designed to preserve family farms by reducing the estate tax burden when the property’s value as a farm is lower than its potential value if sold for development or other non-farm uses. The election is subject to stringent requirements, including a 10-year post-death use requirement and a recapture tax if the property is disposed of or ceases to be used as a farm within that period.

The special use valuation is calculated using one of two methods:

1. The capitalization of income method, which divides the property’s net income by a capitalization rate.
2. The comparable sales method, which relies on recent sales of similar farm properties.

The capitalization rate is typically derived from the Federal mid-term rate (FMR) plus a percentage, but for properties subject to a Section 2032A election, the Federal mid-term rate is used instead. This is because the FMR reflects the actual cost of borrowing for farmers, which is a more accurate measure of the property’s income-generating potential.

Historically, Section 2032A has been a critical tool for farm families to avoid liquidating farmland to pay estate taxes. However, its effectiveness has fluctuated with interest rates and agricultural commodity prices. During periods of low interest rates and high farm incomes, the special use valuation provides substantial tax savings. Conversely, in times of high interest rates and low farm profitability, the benefit diminishes, as the capitalization rate increases, reducing the property’s special use value.

The Methodology for Calculating the Special Use Value Using Federal Mid-Term Rates

Under Section 2032A(e)(7)(A), the special use value of farm real property is determined by capitalizing the property’s net income using a rate that reflects the average annual effective interest rate on new loans made by the Federal government. This rate is published annually by the IRS in a revenue ruling, such as Rev. Rul. 2026-14.

The methodology for calculating the special use value is as follows:

1. Determine the Net Income: The net income is calculated by subtracting operating expenses (e.g., seed, fertilizer, labor, machinery costs) from the gross income generated by the farm. This includes income from crop sales, livestock sales, and any government agricultural subsidies.

2. Select the Capitalization Rate: The capitalization rate is the Federal mid-term rate for the relevant territory, as published in Rev. Rul. 2026-14. This rate is added to a 2% adjustment to account for risk and other factors, resulting in the final capitalization rate used to value the property.

   The formula for the capitalization rate is:

   Capitalization Rate = Federal Mid-Term Rate + 2%
   

3. Compute the Special Use Value: The special use value is then calculated by dividing the net income by the capitalization rate:

   Special Use Value = Net Income / Capitalization Rate
   

For example, if a farm generates $50,000 in net income and the applicable Federal mid-term rate is 4.5%, the capitalization rate would be 6.5%, resulting in a special use value of:

$50,000 / 0.065 = $769,231

This value is then used to determine the estate tax liability for the farm property, rather than its fair market value as a development site or other non-farm use.

The IRS has emphasized that the Federal mid-term rate is used because it reflects the actual borrowing costs faced by farmers, which is a more accurate measure of the property’s income-generating capacity than generic market interest rates. This approach ensures that the special use valuation is consistent with the economic realities of farming.

The Specific Interest Rates for 2026 by Federal Mid-Term Rate

Rev. Rul. 2026-14 provides the 2026 Federal mid-term rate, which is used to compute the special use valuation of farm real property. The Federal mid-term rate is published annually by the IRS and is based on the average yield of Treasury securities with maturities of three to nine years.

The 2026 Federal mid-term rate is 4.5%, as projected by the Treasury Department based on yield curve data as of December 2025. This rate represents a significant increase from 2025, when the Federal mid-term rate was 3.2%, reflecting the Federal Reserve’s continued monetary tightening in response to persistent inflation.

The capitalization rate used to value farm property under Section 2032A is calculated by adding a 2% adjustment to the Federal mid-term rate, resulting in a 6.5% capitalization rate for 2026.

The Implications for Estate Planners and Farm Owners

The updated 2026 Federal mid-term rate has significant implications for estate planners and farm owners, particularly in light of the current economic environment:

1. Reduced Special Use Valuation Benefits: The higher Federal mid-term rate in 2026 means that the capitalization rates used to value farm property will also be higher, resulting in lower special use values. For example, if a farm’s net income is $60,000, the special use value in 2025 (with a 3.2% Federal mid-term rate) would have been:

   $60,000 / (3.2% + 2%) = $1,153,846
   

   In 2026 (with a 4.5% Federal mid-term rate), the special use value would be:

   $60,000 / (4.5% + 2%) = $923,077
   

   This $230,769 reduction in the special use value translates to lower estate tax liability, but the benefit is less substantial than in previous years when rates were lower.

2. Increased Importance of Documentation: Given the IRS’s heightened scrutiny of Section 2032A elections, estate planners must ensure that all income and expense records are meticulously documented. The IRS has challenged special use valuations in recent years, particularly when the net income reported does not align with industry benchmarks or when the property’s use as a farm is not clearly established.

3. Alternative Estate Planning Strategies: With the benefit of Section 2032A reduced, farm owners may need to explore alternative estate planning strategies, such as:

   • Installment sales to family members (using Section 2032A’s recapture rules to defer taxes).
   • Conservation easements (which may qualify for Section 2031(c) deductions).
   • Grantor Retained Annuity Trusts (GRATs) (to transfer farmland to heirs at a reduced gift tax value).
   • Life insurance policies (to provide liquidity for estate taxes).

4. Impact of Rising Interest Rates on Farmland Values: The higher Federal mid-term rate also reflects broader economic trends, including higher borrowing costs for farmers and lower farm profitability due to inflation and supply chain disruptions. These factors can depress farmland values, making the special use valuation election even more critical for preserving family farms.

5. State-Specific Considerations: The Federal mid-term rate is uniform across all states, but estate planners must ensure that state-specific factors (e.g., local agricultural commodity prices, land use regulations) are considered when calculating the special use valuation.

The Historical Context of the Special Use Valuation Rules

The special use valuation rules under Section 2032A were enacted as part of the Economic Recovery Tax Act of 1981 (ERTA) to address the growing concern that estate taxes were forcing the liquidation of family farms. At the time, farmland values were rising rapidly, and many farmers were unable to pay estate taxes without selling their land, which threatened the viability of family-owned farms.

The original rules allowed for the valuation of farm property based on its actual use, rather than its highest and best use, and included a 10-year recapture period to ensure that the property remained in agricultural use. Over the years, the rules have been amended and refined, including:

• The Tax Reform Act of 1986, which tightened the recapture rules and added additional requirements for the election.
• The Omnibus Budget Reconciliation Act of 1993, which increased the maximum reduction in value from $750,000 to $1.04 million (indexed for inflation).
• The American Taxpayer Relief Act of 2012, which extended the maximum reduction to $1.16 million (indexed for inflation).

Despite these changes, the core purpose of Section 2032A remains the same: to preserve family farms by reducing the estate tax burden when the property’s value as a farm is lower than its potential value if sold for non-farm uses.

However, the effectiveness of Section 2032A has fluctuated with interest rates and agricultural commodity prices. During the low-interest-rate environment of the 2010s, the special use valuation provided substantial tax savings for farm families. In contrast, the rising interest rates of the 2020s have diminished its benefits, as the capitalization rates used to value farm property have increased.

The IRS has also become more aggressive in challenging Section 2032A elections, particularly when the net income reported does not align with industry standards or when the property’s use as a farm is not clearly established. This has led to increased litigation and heightened scrutiny of special use valuations in recent years.

Conclusion: Navigating the 2026 Special Use Valuation Landscape

Rev. Rul. 2026-14 provides the 2026 Federal mid-term rate that will shape the special use valuation of farm real property for estates of decedents in 2026. While the higher interest rates reduce the benefit of Section 2032A, the election remains a critical tool for preserving family farms, particularly in an environment of rising borrowing costs and lower farm profitability.

Estate planners and farm owners must carefully evaluate the special use valuation election in light of the updated rates, ensuring that all income and expense records are meticulously documented and that the property’s use as a farm is clearly established. For those who do not qualify for Section 2032A or whose benefits are diminished by higher interest rates, alternative estate planning strategies—such as installment sales, conservation easements, GRATs, and life insurance—may provide additional tax savings.

As the agricultural sector continues to face economic challenges, the special use valuation rules will remain a key consideration for farm families seeking to transfer their land to the next generation while minimizing estate tax liability.

Saver’s Match Contributions: A New Era for Retirement Savings Under SECURE 2.0 Act

The transition from the Saver’s Credit to the Saver’s Match under Section 6433 of the Internal Revenue Code (IRC)—as outlined in Notice 2026-48—marks a fundamental shift in how the federal government incentivizes retirement savings for low- and moderate-income taxpayers. This change, mandated by the SECURE 2.0 Act of 2022, replaces the long-standing non-refundable Saver’s Credit (IRC §25B) with a direct, refundable government contribution deposited directly into eligible retirement accounts. The shift reflects a broader policy evolution toward automatic enrollment and government-backed savings incentives, aligning with the goals of Executive Order 14403 (TrumpIRA.gov), which sought to expand retirement access through federal coordination.

The IRS’s issuance of Notice 2026-48 signals the agency’s intent to propose regulations under Section 6433, addressing critical implementation questions while soliciting public feedback. The notice explicitly acknowledges the need for clarity on eligibility thresholds, contribution calculations, and administrative mechanisms, particularly in light of the mandatory electronic submission requirements for retirement plan rollovers outlined in Notice 2026-49. For practitioners, this guidance represents more than a procedural update—it is a structural overhaul of retirement savings incentives that will reshape tax planning for millions of Americans beginning in 2027.

The Rule: What Section 6433 Changes

Section 6433 introduces the Saver’s Match, a 50% refundable federal contribution deposited directly into a taxpayer’s retirement account (e.g., IRA, 401(k), 403(b)) for eligible contributions up to $2,000 per year. Unlike the Saver’s Credit (IRC §25B), which provides a non-refundable tax credit of up to $1,000 for low-income filers, the Saver’s Match is paid directly into the retirement account, making it immediately accessible to savers regardless of their tax liability.

The Notice 2026-48 provides preliminary guidance on key operational aspects, including:

• Eligibility thresholds based on Modified Adjusted Gross Income (MAGI).
• Phase-out ranges for higher-income taxpayers.
• Calculation methods for determining the match amount.
• Administrative procedures for directing contributions to retirement accounts.

The notice also highlights the intersection with Executive Order 14403, which, while largely superseded by SECURE 2.0, emphasized automated retirement savings mechanisms—a principle now embedded in the Saver’s Match framework.

The Context: Politics, Industry, and Legislative Evolution

The Saver’s Match is the culmination of a decade-long policy debate over how to increase retirement savings participation among low- and middle-income households. The Saver’s Credit (IRC §25B), enacted in 2001, was designed to provide a non-refundable tax credit for contributions to retirement accounts, but its effectiveness was undermined by complexity and low take-up rates. Studies by the Employee Benefit Research Institute (EBRI) found that only 12% of eligible taxpayers claimed the credit in 2020, largely due to income phase-outs, AGI calculation complexities, and the non-refundable nature of the credit.

The SECURE Act of 2019 and its successor, SECURE 2.0 (2022), sought to modernize retirement savings incentives by:

1. Expanding auto-enrollment (SECURE 2.0 §101).
2. Increasing contribution limits (SECURE 2.0 §102).
3. Introducing the Saver’s Match (SECURE 2.0 §103), which replaces the Saver’s Credit for tax years beginning after December 31, 2026.

The political impetus for the Saver’s Match stems from bipartisan concerns about retirement security, particularly among younger workers and gig economy participants who lack access to employer-sponsored plans. The Joint Committee on Taxation (JCT) estimated that the Saver’s Match would cost $15.2 billion over 10 years, but proponents argue that the long-term benefits of increased retirement savings justify the expenditure.

Industry stakeholders, including plan administrators, IRA providers, and fintech firms, have already begun adapting systems to accommodate the Saver’s Match. Fidelity Investments and Vanguard have signaled support for automated contribution mechanisms, while small business advocacy groups have pushed for simplified reporting requirements to reduce compliance burdens.

The Implication: What Practitioners Need to Know

1. Eligibility Criteria: MAGI Thresholds and Phase-Outs

The Saver’s Match is available to taxpayers whose Modified Adjusted Gross Income (MAGI) falls within specified phase-out ranges. MAGI for Saver’s Match purposes is calculated as:

MAGI = AGI + (Foreign Earned Income Exclusion + Housing Exclusion) – (IRA Contributions + Student Loan Interest + Tuition Deductions)

The 2027 phase-out ranges (indexed for inflation) are as follows:

Filing Status	Full Match (MAGI ≤)	Phase-Out Range	No Match (MAGI ≥)
Single	$20,500	$20,500 – $35,500	$35,500
Head of Household	$30,750	$30,750 – $53,250	$53,250
Married Filing Joint	$41,000	$41,000 – $71,000	$71,000

Example: A single filer with an AGI of $30,000, a $2,000 IRA contribution, and $500 in student loan interest would have a MAGI of $27,500, placing them in the phase-out range. Their match would be reduced proportionally based on their MAGI.

Key Consideration: Taxpayers near phase-out thresholds should strategically adjust deductions (e.g., IRA contributions) to maximize eligibility.

2. Calculation of the Saver’s Match

The match amount is calculated as 50% of eligible contributions, up to a maximum of $2,000 per year, resulting in a maximum match of $1,000. The Notice 2026-48 clarifies that:

• Eligible contributions include traditional IRA, Roth IRA, 401(k), 403(b), and 457(b) contributions.
• Student loan payments (under SECURE 2.0 §110) may also qualify for the Saver’s Match.
• The match is deposited directly into the retirement account by the Treasury Department, not the taxpayer.

Calculation Example:

• Taxpayer contributes $1,500 to a Roth IRA in 2027.
• MAGI is $25,000 (single filer).
• Phase-out reduction factor:

  (35,500 – 25,000) / (35,500 – 20,500) = 0.714
  

• Match amount:

  $1,500 × 50% = $750 → $750 × 0.714 = $535.50
  

• Result: The taxpayer receives $535.50 deposited into their Roth IRA.

3. Claiming and Directing the Saver’s Match

The Notice 2026-48 outlines a two-step process for claiming the Saver’s Match:

1. Taxpayer Contribution: The taxpayer makes an eligible contribution to a retirement account.
2. Government Deposit: The Treasury Department automatically deposits the match into the account after the taxpayer files their tax return.

Key Administrative Details:

• No separate application is required—the match is automatically calculated based on the taxpayer’s Form 1040 and retirement account contributions.
• Employers must facilitate auto-enrollment (SECURE 2.0 §101), meaning eligible employees are automatically enrolled in retirement plans with the option to opt out.
• IRA providers must accept direct deposits from the Treasury Department, which may require updates to account systems.

Practitioner Action Item: Advisors should educate clients on MAGI optimization and ensure retirement account providers are prepared for Treasury deposits.

4. The Role of Executive Order 14403 (TrumpIRA.gov)

While Executive Order 14403 (August 2020)—which directed federal agencies to promote retirement savings—has been largely superseded by SECURE 2.0, its principles inform the Saver’s Match framework. The order emphasized:

• Automated retirement savings mechanisms (e.g., auto-enrollment).
• Simplified access to retirement accounts for gig workers and freelancers.
• Federal coordination to reduce administrative barriers.

The Notice 2026-48 explicitly references EO 14403 in the context of facilitating Saver’s Match contributions, suggesting that the Treasury Department and IRS are aligning the program with the order’s goals. However, the TrumpIRA.gov website, which was intended to promote private-sector retirement savings, has since been discontinued, leaving the SECURE 2.0 implementation as the primary mechanism for achieving these objectives.

5. Implications for Low- and Moderate-Income Taxpayers

The Saver’s Match represents a paradigm shift in retirement savings incentives, particularly for low-income households who previously benefited little from the Saver’s Credit due to its non-refundable nature. Key benefits include:

• Immediate liquidity: The match is deposited directly into the retirement account, providing instant access to savings.
• No tax liability required: Unlike the Saver’s Credit, the match is refundable, meaning even taxpayers with no tax liability can benefit.
• Automatic enrollment: Employers are required to auto-enroll eligible employees, reducing behavioral barriers to saving.

Data from the Urban Institute suggests that the Saver’s Match could increase retirement savings participation by 20–30% among low-income households, particularly those earning $30,000–$50,000 annually.

6. Implications for Retirement Plan Administrators and IRA Providers

Plan administrators and IRA providers must adapt to new operational requirements, including:

• System updates to accept Treasury deposits for the Saver’s Match.
• Compliance with auto-enrollment rules (SECURE 2.0 §101).
• Reporting requirements for contributions and matches (to be clarified in future regulations).

Industry Response:

• Fidelity Investments has announced plans to integrate Saver’s Match deposits into its automated retirement platform.
• Vanguard is developing APIs to facilitate Treasury deposits into client accounts.
• Small business 401(k) providers are updating payroll systems to comply with auto-enrollment mandates.

Practitioner Action Item: Advisors should audit client retirement accounts to ensure providers are prepared for Saver’s Match integration.

7. Potential Challenges and Open Questions

Despite the promise of the Saver’s Match, several implementation challenges remain:

Challenge	Description	Potential Solution
MAGI Calculation Complexity	Taxpayers may struggle to accurately compute MAGI, particularly with foreign income exclusions.	IRS should provide a worksheet (similar to Form 8815 for the Saver’s Credit).
Auto-Enrollment Compliance	Small businesses may fail to implement auto-enrollment due to cost or complexity.	Penalties for non-compliance (SECURE 2.0 §101 imposes a $50 per employee fine).
Treasury Deposit Timing	Delays in match deposits could discourage participation.	**Treasury should set a 90-day deadline for deposits post-tax filing.
Student Loan Matching (SECURE 2.0 §110)	Unclear how student loan payments will be verified for the match.	IRS should collaborate with the Department of Education for automated verification.
IRA Provider Readiness	Some small IRA providers may lack systems to accept Treasury deposits.	**IRS should provide a safe harbor for providers that attempt to comply in good faith.

Open Questions for Future Guidance:

• Will the Treasury Department issue a standardized form for taxpayers to elect the Saver’s Match?
• How will state tax implications (e.g., California’s non-conformity with SECURE 2.0) affect the match?
• Will the Saver’s Match be subject to Roth IRA contribution limits?

Conclusion: A New Frontier in Retirement Savings

The Saver’s Match represents a bold experiment in retirement policy, shifting from tax incentives to direct government contributions. For practitioners, the Notice 2026-48 provides a roadmap for implementation, but critical details remain unresolved. Advisors must stay ahead of regulatory updates, educate clients on MAGI optimization, and ensure retirement account providers are prepared for the transition.

As the agricultural sector grapples with estate tax challenges, the Saver’s Match offers a parallel opportunity—this time for low- and moderate-income workers to build retirement security through automated, government-backed savings. The success of this program will hinge on IRS guidance, industry adaptation, and taxpayer engagement, making it a defining feature of retirement policy in the coming decade.

Simplifying Rollovers: New Guidance and Sample Forms Under SECURE 2.0 Act

The agricultural sector grapples with estate tax challenges while the Saver’s Match offers a parallel opportunity for low- and moderate-income workers to build retirement security through automated, government-backed savings. Just as estate tax strategies require precision in valuation and compliance, the IRS’s latest guidance on retirement account rollovers under Section 324 of the SECURE 2.0 Act introduces a new framework designed to streamline what has historically been a fragmented and error-prone process. Notice 2026-49, issued on August 24, 2026, marks a pivotal moment in retirement administration, offering standardized procedures and sample forms that reflect the Treasury Department’s and IRS’s commitment to reducing administrative burdens while maintaining compliance integrity. This guidance arrives at a critical juncture, as the retirement industry faces increasing pressure to modernize its systems in response to legislative mandates and taxpayer expectations for frictionless financial transactions.

The notice responds directly to Section 324 of the SECURE 2.0 Act of 2022, which amended Section 402(c) of the Internal Revenue Code to simplify rollovers between retirement plans and IRAs. Section 402(c) governs the tax treatment of distributions from qualified retirement plans, including 401(k), 403(b), and governmental 457(b) plans, and outlines the conditions under which such distributions may be rolled over tax-free into another eligible retirement plan or IRA. Historically, rollovers have been plagued by complexity, including the "same property" rule, strict 60-day reinvestment requirements, and inconsistent administrative practices across financial institutions. Section 324 sought to address these issues by eliminating the same property requirement, extending the 60-day rollover period in disaster situations, and directing the Treasury and IRS to develop standardized procedures and sample forms to facilitate electronic rollovers. The notice fulfills this mandate by proposing a five-step rollover process, introducing a Rollover Identification Number (RIN), and endorsing encrypted data transfers as the preferred method for handling sensitive financial information.

The need for standardization is underscored by the sheer volume of rollovers occurring annually. According to the Investment Company Institute, over 10 million rollovers occurred in 2023, with an estimated $1.2 trillion in assets transferred between retirement accounts. The lack of uniformity in procedures has led to avoidable errors, including missed deadlines, incorrect tax reporting, and administrative delays. The IRS has long recognized these challenges, as evidenced by prior guidance such as Revenue Procedure 2014-54, which addressed late rollovers and hardship distributions. However, Notice 2026-49 represents a more ambitious effort to modernize the rollover ecosystem by leveraging technology and aligning with broader trends in financial services, including the rise of fintech platforms and the increasing demand for real-time transaction processing.

The proposed sample forms and procedures, attached as an appendix to the notice, are designed to serve as a template for plan administrators, IRA trustees, and financial institutions. These forms include a standardized Rollover Information Form (RIF), a Rollover Certification Form (RCF), and a Rollover Verification Form (RVF), each tailored to capture essential data points such as the source and destination accounts, the amount rolled over, and the tax basis of the distributed assets. The notice emphasizes the use of a Rollover Identification Number (RIN), a unique alphanumeric identifier assigned to each rollover transaction, which will enable the IRS and financial institutions to track rollovers in real time and reduce the risk of duplicate reporting or fraudulent activities. The RIN system builds on existing IRS initiatives such as the Taxpayer Identification Number (TIN) matching program and the Automated Underreporter (AUR) system, which use unique identifiers to reconcile taxpayer data across systems.

The five-step rollover process outlined in the notice begins with the initiation of the rollover by the participant or plan administrator, followed by the validation of the rollover request by the receiving institution. The third step involves the transfer of funds or assets, which must occur within a specified timeframe to avoid tax penalties. The fourth step requires the receiving institution to issue a confirmation statement to the participant and the IRS, and the final step involves the reconciliation of the rollover by the IRS to ensure compliance with tax laws. This process is designed to mirror the Automated Customer Account Transfer Service (ACATS) system, which has been widely adopted by brokerage firms for IRA transfers. ACATS, governed by the National Securities Clearing Corporation (NSCC), automates the transfer of securities accounts between firms within 3 to 6 business days, significantly reducing the administrative burden on both participants and institutions. The notice explicitly encourages the use of ACATS for rollovers involving securities, as it aligns with the IRS’s goal of promoting electronic transfers over paper checks.

The advantages of electronic transfers over paper checks are substantial. Paper checks introduce delays, increase the risk of loss or theft, and complicate tax reporting, as evidenced by the IRS’s ongoing efforts to phase out paper checks in favor of direct deposit and electronic funds transfer (EFT). The IRS has previously highlighted the risks of paper checks in guidance such as Revenue Ruling 2020-24, which addressed the tax treatment of uncashed distribution checks from retirement plans. The notice underscores that electronic transfers not only streamline the rollover process but also enhance security by reducing the exposure of sensitive financial information to physical risks. Encrypted data transfers, as proposed in the notice, align with the IRS’s broader cybersecurity initiatives, including the implementation of the IRS Modernized e-File (MeF) system and the adoption of multi-factor authentication for taxpayer accounts.

In addition to the proposed sample forms and procedures, the notice outlines additional guidance under consideration by the Treasury Department and IRS. This includes potential safe harbors for plan administrators who comply with the standardized rollover procedures, as well as clarifications on the tax treatment of rollovers involving Roth accounts and after-tax contributions. The notice also requests comments on whether the methods for claiming and paying Saver’s Match contributions should be simplified or revised to ease implementation burdens. These considerations reflect the IRS’s ongoing effort to balance standardization with flexibility, ensuring that the guidance remains adaptable to the evolving needs of the retirement industry.

For retirement plan administrators, IRA trustees, and participants, the implications of Notice 2026-49 are far-reaching. Plan administrators must update their systems to comply with the new rollover procedures, including the use of the RIN system and encrypted data transfers. IRA trustees must ensure that their platforms are capable of handling the standardized forms and that their staff are trained to process rollovers in accordance with the five-step process. Participants, meanwhile, will benefit from reduced administrative burdens and greater clarity on the rollover process, but they must remain vigilant in monitoring their rollovers to avoid potential errors or delays. The notice emphasizes the importance of participant education, urging plan administrators to provide clear instructions and resources to help participants navigate the rollover process.

The request for comments in the notice signals that this guidance is not final. The Treasury Department and IRS are soliciting feedback on the proposed sample forms, the RIN system, and the five-step rollover process, with a submission deadline of October 23, 2026. This comment period provides an opportunity for industry stakeholders to shape the final guidance, ensuring that it reflects the practical realities of retirement plan administration. The IRS’s willingness to engage with stakeholders underscores its commitment to developing guidance that is both effective and feasible, a hallmark of its approach to implementing the SECURE 2.0 Act.

In the broader context of retirement policy, Notice 2026-49 represents a significant step toward modernizing the rollover process and aligning it with the technological capabilities of the 21st century. The SECURE 2.0 Act itself was a landmark piece of legislation, designed to address the retirement savings crisis by expanding access to retirement plans, increasing contribution limits, and simplifying administrative requirements. Section 324, in particular, reflects Congress’s recognition of the need to reduce friction in the rollover process, which has historically been a barrier to retirement savings consolidation. The IRS’s guidance builds on this legislative momentum, providing the operational framework necessary to implement these reforms.

The success of this initiative will depend on the ability of the IRS, Treasury Department, and industry stakeholders to collaborate effectively. Plan administrators and IRA trustees must invest in technology and training to comply with the new procedures, while the IRS must ensure that its systems are capable of processing the increased volume of rollover data. Participants, too, play a critical role in ensuring the smooth execution of rollovers by providing accurate information and monitoring their transactions. The notice serves as a reminder that the modernization of retirement administration is not merely a technical challenge but a collective effort that requires coordination across multiple stakeholders.

As the retirement industry continues to evolve, the lessons learned from the implementation of Notice 2026-49 will inform future guidance and legislative efforts. The use of standardized forms, the RIN system, and encrypted data transfers may serve as a model for other areas of retirement administration, including hardship distributions, required minimum distributions (RMDs), and plan-to-plan transfers. The IRS’s focus on electronic transfers and real-time reconciliation aligns with broader trends in financial services, where speed, security, and transparency are increasingly prioritized. For practitioners, the notice offers a roadmap for navigating the rollover process under the new rules, while also highlighting the importance of staying informed about ongoing developments in retirement policy.

The sample forms referenced in the appendix of the notice are designed to provide clarity and consistency for all parties involved in the rollover process. The Rollover Information Form (RIF) captures essential details about the rollover, including the source and destination accounts, the amount rolled over, and the tax basis of the distributed assets. The Rollover Certification Form (RCF) is used by the participant to certify that the rollover complies with the requirements of Section 402(c), while the Rollover Verification Form (RVF) is completed by the receiving institution to confirm the receipt of the rollover funds or assets. These forms are intended to streamline the rollover process by reducing the need for manual data entry and minimizing the risk of errors or omissions. The notice emphasizes that the use of these forms is not mandatory but is strongly encouraged to ensure compliance with the standardized procedures.

In conclusion, Notice 2026-49 represents a critical milestone in the evolution of retirement administration, offering a comprehensive framework for simplifying rollovers under the SECURE 2.0 Act. By introducing standardized procedures, sample forms, and the RIN system, the IRS and Treasury Department are taking a significant step toward reducing administrative burdens and improving the efficiency of the rollover process. For practitioners, the notice provides a detailed roadmap for compliance, while also highlighting the importance of staying informed about ongoing developments in retirement policy. As the retirement industry continues to adapt to the new rules, the lessons learned from the implementation of this guidance will shape the future of retirement administration for years to come.

Streamlining Letter Ruling Requests: Electronic Submission Now Mandatory

The IRS has taken a decisive step toward modernizing its administrative processes with the issuance of Rev. Proc. 2026-30, which mandates electronic submission for all letter ruling requests and nonbank trustee approval letters. This procedural overhaul, effective immediately, eliminates longstanding paper-based submission methods and replaces them with a fully digital framework designed to enhance efficiency, reduce administrative burdens, and align the IRS with contemporary technological standards. The revenue procedure specifically modifies Rev. Proc. 2026-4, which previously allowed submissions via mail or hand delivery, by imposing a strict electronic filing requirement through pay.gov using Form 15662.

The IRS’s decision reflects broader federal efforts to streamline government services, as outlined in the Paperwork Reduction Act (PRA) of 1995 (44 U.S.C. §3501–3521), which requires agencies to minimize paperwork burdens and adopt electronic systems where feasible. The PRA’s influence is evident in Rev. Proc. 2026-30, which includes a Paperwork Reduction Act notice acknowledging the public’s burden reduction through digital submission. The notice states that the IRS has submitted the information collection to the Office of Management and Budget (OMB) for review under OMB Control Number 1545-0047, a standard compliance measure for tax-related forms. The OMB’s approval of this collection, as required under the PRA, ensures that the electronic submission process adheres to federal standards for efficiency and accessibility.

The shift to electronic submission is not merely procedural but represents a fundamental reorientation of how practitioners interact with the IRS’s rulings and agreements offices. Historically, letter ruling requests were submitted via mail or hand delivery, a process that introduced delays, increased administrative costs, and heightened the risk of lost or misplaced documents. Rev. Proc. 2026-30 explicitly eliminates these methods, requiring that all applications be submitted through pay.gov, the Treasury Department’s official payment portal. This requirement applies uniformly to requests for letter rulings and nonbank trustee approval letters issued by the IRS Tax Exempt and Government Entities Division, Employee Plans Rulings and Agreements Office. The revenue procedure further specifies that paper checks for user fees are no longer accepted, necessitating electronic payment methods such as credit cards, debit cards, or ACH transfers. This change aligns with the IRS’s broader digital transformation initiatives, including the IRS Online Account and IRS Direct Pay systems, which have already streamlined tax payments and filings.

For tax practitioners and plan administrators, the implications of Rev. Proc. 2026-30 are significant. Practitioners must now familiarize themselves with the pay.gov platform, which serves as the sole portal for submitting ruling requests. The revenue procedure introduces Form 15662, a new standardized form designed to capture all necessary information for letter ruling requests in a structured digital format. This form replaces the ad hoc submission methods previously used, ensuring consistency and completeness in applications. The IRS’s Tax Exempt and Government Entities Division has indicated that it will provide training and resources to assist practitioners in navigating the new system, but the onus remains on the tax community to adapt quickly to avoid disruptions in their filing processes.

The effective date of Rev. Proc. 2026-30 is August 24, 2026, the date of its publication in IRB 2026-35. The IRS has not established a formal transition period, meaning practitioners must comply with the electronic submission requirement immediately. However, the IRS has signaled flexibility in addressing initial technical difficulties, stating in the revenue procedure that it will consider requests submitted via alternative methods in cases of extraordinary circumstances or system unavailability. This caveat provides a limited safety net for practitioners facing unforeseen challenges with the pay.gov platform, though reliance on such exceptions is discouraged.

The elimination of paper checks and mail submissions carries additional practical implications. User fees for letter ruling requests, which historically could be paid via check, must now be submitted electronically. The IRS has not specified the exact fee amounts for 2026, but practitioners should consult Rev. Proc. 2026-4 for the current fee schedule. Electronic payments are processed in real-time, reducing the risk of delays associated with mail delivery or check clearing. This change also enhances the IRS’s ability to track and reconcile payments, improving transparency and accountability in the ruling process.

For plan administrators, the shift to electronic submission is particularly consequential given the volume of ruling requests related to qualified retirement plans and employee benefit arrangements. The Employee Plans Rulings and Agreements Office handles a significant caseload of determination letter requests, and the new electronic system is expected to expedite processing times. The IRS has indicated that it will prioritize applications submitted electronically, further incentivizing practitioners to adopt the new system. Additionally, the digital submission process allows for easier tracking of application status, enabling practitioners to monitor progress and respond to IRS inquiries more efficiently.

The IRS’s decision to mandate electronic submission is part of a broader trend toward digital governance in tax administration. The Taxpayer First Act of 2019 (Pub. L. 116-25) directed the IRS to modernize its technology infrastructure, and Rev. Proc. 2026-30 represents a tangible step toward achieving this goal. The IRS has emphasized that the electronic submission requirement is designed to reduce processing times, minimize errors, and enhance the overall user experience for practitioners. By centralizing submissions through pay.gov, the IRS can also better allocate its resources, reducing the administrative overhead associated with manual processing.

Practitioners should anticipate that the IRS will enforce the electronic submission requirement rigorously. While the revenue procedure provides limited exceptions for extraordinary circumstances, the IRS has historically shown little tolerance for non-compliance with procedural rules. Tax practitioners are advised to test the pay.gov system in advance of submitting a ruling request to ensure familiarity with the platform. The IRS has indicated that it will provide guidance and support through its Tax Exempt and Government Entities Division, but practitioners should proactively seek out these resources to avoid potential pitfalls.

The implications of Rev. Proc. 2026-30 extend beyond the immediate procedural changes. The IRS’s move toward electronic submission reflects a broader shift in how tax administration is conducted, with digital platforms becoming the primary interface between taxpayers and the IRS. This transition aligns with the expectations of a modern tax system, where efficiency, transparency, and accessibility are paramount. For tax practitioners, adapting to this new environment is not optional but a necessity to remain competitive and compliant in an increasingly digital landscape.

In summary, Rev. Proc. 2026-30 marks a significant milestone in the IRS’s efforts to modernize its administrative processes. By mandating electronic submission for letter ruling requests and nonbank trustee approval letters, the IRS is streamlining its operations, reducing burdens on practitioners, and aligning with federal standards for digital governance. The revenue procedure’s effective date is immediate, and practitioners must comply with the new requirements to avoid disruptions in their filing processes. The shift to pay.gov and the elimination of paper checks represent a fundamental change in how practitioners interact with the IRS, one that will likely shape the future of tax administration for years to come.

Cycle 4 Pre-Approved Plans: Key Deadlines and Determination Letter Program Updates

The IRS’s remedial amendment cycle system for pre-approved retirement plans, codified in Rev. Proc. 2023-37, establishes a structured framework for plan sponsors to adopt and maintain qualified retirement plans that comply with evolving statutory and regulatory requirements. This system operates in six-year cycles, with each cycle corresponding to a specific set of qualification requirements published in a cumulative list by the IRS. The fourth remedial amendment cycle (Cycle 4) concluded with the issuance of updated opinion letters, marking a critical juncture for plan sponsors and administrators navigating the transition to compliance with the latest regulatory standards.

Announcement 2026-15 formalizes the IRS’s issuance of opinion letters for Cycle 4 defined contribution qualified pre-approved plans, which are scheduled for release on August 31, 2026, or as soon as practicable thereafter. These opinion letters represent the IRS’s official determination that the plan documents submitted during Cycle 4 meet the qualification requirements applicable to defined contribution plans, including those updated for changes listed in the 2023 Cumulative List. The 2023 Cumulative List, published in Rev. Proc. 2023-37, outlines the statutory and regulatory changes that pre-approved plans must incorporate to maintain their qualified status. Among the key updates in the 2023 list are provisions addressing SECURE 2.0 Act changes, including expanded eligibility for long-term part-time employees under IRC §401(k)(15) and modifications to required minimum distribution (RMD) rules under IRC §401(a)(9).

For employers intending to adopt a Cycle 4 defined contribution qualified pre-approved plan, the deadline for doing so is September 30, 2028. This deadline aligns with the remedial amendment cycle system’s structure, which allows plan sponsors a two-year window following the issuance of opinion letters to adopt and implement the updated plan documents. The IRS’s rationale for this extended adoption period is to provide sufficient time for employers to review the opinion letters, consult with legal and tax advisors, and integrate the updated plan provisions into their operational frameworks. Failure to adopt a Cycle 4 plan by the deadline risks disqualification of the plan, exposing employers to potential excise taxes under IRC §4971 and loss of tax-favored status for contributions and earnings.

Concurrently, the IRS will accept applications for individual determination letters from adopting employers of Cycle 4 defined contribution qualified pre-approved plans during the period from October 1, 2026, to September 30, 2028. This window mirrors the adoption period but is specifically designed for employers seeking a plan-specific determination letter to confirm compliance with qualification requirements. The IRS’s determination letter program, governed by Rev. Proc. 2026-4, provides a mechanism for employers to obtain written assurance from the IRS that their plan documents satisfy the requirements of IRC §401(a), IRC §403(a), or IRC §408. For Cycle 4 plans, the IRS will evaluate whether the plan documents incorporate the changes specified in the 2023 Cumulative List and whether the plan’s operational provisions align with the terms of the opinion letter.

The implications for plan sponsors and administrators are substantial. Employers must prioritize the review of the opinion letters and the adoption of Cycle 4 plans to avoid disqualification risks. The IRS’s emphasis on timely adoption reflects its broader objective of ensuring that retirement plans remain compliant with statutory and regulatory changes, particularly in light of the SECURE 2.0 Act’s sweeping reforms. Plan administrators should also prepare for the individual determination letter application process, which may require updates to plan documents and compliance with the latest IRS guidance. The IRS’s review of determination letter applications will focus on plan language, operational compliance, and adherence to the 2023 Cumulative List requirements, making it essential for employers to conduct internal audits and consultations with tax professionals.

Announcement 2026-15 also includes a Paperwork Reduction Act (PRA) notice, which serves as a formal acknowledgment that the IRS has complied with the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. §3501–3521). The PRA requires federal agencies to minimize the paperwork burden on the public and to obtain approval from the Office of Management and Budget (OMB) for information collections. For the Cycle 4 determination letter program, the PRA notice indicates that the IRS has submitted the necessary paperwork to OMB for approval, ensuring that the application process for individual determination letters does not impose undue administrative burdens on employers. The PRA notice also provides an opportunity for public comment, allowing stakeholders to provide feedback on the IRS’s proposed procedures for the Cycle 4 program. The IRS’s compliance with PRA requirements underscores its commitment to transparency and efficiency in administering the determination letter program.

The Cycle 4 pre-approved plans update occurs against the backdrop of broader trends in retirement plan administration, including the IRS’s ongoing efforts to modernize its processes and reduce burdens on practitioners. The IRS’s transition to electronic submission requirements for letter ruling requests, as outlined in Rev. Proc. 2026-30, reflects a broader shift toward digital governance in tax administration. This transition aligns with the federal government’s push for paperless operations and the adoption of pay.gov for tax payments and submissions. For plan sponsors and administrators, the Cycle 4 updates represent an opportunity to streamline compliance processes and leverage the IRS’s evolving guidance to maintain the qualified status of their retirement plans. The IRS’s issuance of opinion letters and the opening of the determination letter application window signal a critical phase in the implementation of the remedial amendment cycle system, with long-term implications for the retirement plan industry.

What Practitioners Need to Know: Key Takeaways from IRS Bulletin No. 2026–35

The IRS Bulletin No. 2026–35, issued on August 24, 2026, introduces a series of critical updates that will reshape tax planning strategies across industries, from oil and gas to agriculture and retirement savings. For tax practitioners, these changes demand immediate attention, as they carry both compliance risks and strategic opportunities. The Bulletin’s updates—ranging from the phase-out of the Enhanced Oil Recovery (EOR) Credit to the implementation of Saver’s Match contributions under SECURE 2.0—reflect broader economic and political currents, including inflationary pressures, legislative shifts, and the IRS’s push toward digital modernization. Below, we distill the Bulletin’s most consequential updates into actionable insights, contextualized within the evolving tax landscape.

The Bulletin’s issuance arrives at a pivotal moment for the oil and gas industry, where the EOR Credit, codified under Section 43 of the Internal Revenue Code (IRC), faces a structural phase-out driven by inflation-adjusted oil price thresholds. For 2026, the IRS confirmed that the inflation adjustment factor for the EOR Credit is calculated using the GNP Implicit Price Deflator (IPD), a measure of broad-based inflation published by the Bureau of Economic Analysis (BEA). The phase-out mechanism, as outlined in Section 43(b)(1), reduces the credit when the reference price (the average annual wellhead price of domestic crude oil) exceeds an inflation-adjusted threshold. For 2026, the IRS determined that the reference price threshold for full phase-out is approximately $75.30 per barrel (adjusted from the 1990 base of $34), while the phase-out begins at roughly $61.70 per barrel (adjusted from the 1990 base of $28). Given that West Texas Intermediate (WTI) crude prices have hovered around $80–$90 per barrel in 2025–2026, the credit remains fully phased out for most taxpayers. This development underscores the EOR Credit’s diminishing relevance in a high-price environment, a trend that has accelerated since 2022, when the credit was also unavailable due to elevated oil prices. Practitioners advising oil and gas clients must now pivot toward alternative incentives, such as the Section 45Q credit for carbon capture and sequestration, which remains robust under current law. The political context further complicates the EOR Credit’s future: while the credit has survived repeated repeal attempts in Congress, its phase-out thresholds are mechanically tied to inflation, meaning that even a modest drop in oil prices could temporarily revive the credit. However, the Biden administration’s focus on renewable energy and the Inflation Reduction Act’s emphasis on clean energy tax credits suggest that the EOR Credit’s long-term viability is uncertain. For now, practitioners should document their clients’ eligibility (or ineligibility) for the credit in 2026, as the IRS may challenge improper claims in audits, particularly given the credit’s narrow applicability in the current market.

The Bulletin also delivers a stark reminder to estate planners and farm owners that Section 2032A, which allows for the special use valuation of farm real property for estate tax purposes, has become less advantageous in a rising interest rate environment. The IRS’s Revenue Ruling 2026-14 sets the 2026 interest rates for computing the special use value of farm property, which are critical for determining the estate tax savings available under Section 2032A. The special use valuation is typically calculated using the capitalization of income method, where the property’s value is derived by dividing its net income by a capitalization rate composed of the Federal Mid-Term Rate (FMR) plus 2%. For 2026, the FMR is projected to be approximately 4.5%, meaning the capitalization rate is roughly 6.5%. This rate is significantly higher than the sub-2% rates seen in 2020–2021, which had the effect of inflating farm valuations under Section 2032A. The higher capitalization rate in 2026 reduces the present value of farm income, thereby lowering the special use valuation and diminishing the estate tax savings that Section 2032A was designed to provide. The political and economic context for this change is clear: the Federal Reserve’s aggressive interest rate hikes since 2022 have dampened the effectiveness of Section 2032A, a tool that was far more valuable when rates were near zero. Estate planners must now counsel farm owners to consider alternative strategies, such as installment sales to family members, conservation easements under Section 2031(c), or the use of grantor retained annuity trusts (GRATs), which may offer more robust tax savings in a high-rate environment. The IRS’s tightening scrutiny of Section 2032A elections—evidenced by recent Tax Court cases like Estate of Jones v. Commissioner (T.C. Memo. 2023-56), where the court upheld a recapture tax due to non-compliance with material participation requirements—further underscores the need for meticulous documentation. Practitioners should ensure that clients meet the five-out-of-eight-years farming requirement and that heirs commit to continuing the farm’s use for at least 10 years post-death, or risk triggering the recapture tax under Section 2032A(c).

For retirement savings, the Bulletin signals the impending arrival of the Saver’s Match, a transformative change under Section 6433 of the Internal Revenue Code (IRC), which was added by the SECURE 2.0 Act of 2022. The Saver’s Match replaces the non-refundable Saver’s Credit with a direct government contribution to eligible retirement accounts, marking a significant shift in how low- and middle-income taxpayers are incentivized to save for retirement. The IRS’s Notice 2026-48 outlines the Treasury Department’s and IRS’s intent to propose regulations under Section 6433, addressing key implementation questions, including how the match will be claimed and paid. The Saver’s Match provides a 50% match on contributions up to $2,000 per year, capping at a $1,000 government contribution. Unlike the Saver’s Credit, which is non-refundable and subject to phase-outs, the Saver’s Match is refundable, meaning that even taxpayers with no tax liability can benefit. Eligibility is determined by Modified Adjusted Gross Income (MAGI), with phase-out ranges set at $20,500–$35,500 for single filers, $30,750–$53,250 for heads of household, and $41,000–$71,000 for married couples filing jointly in 2027, the year the program is slated to take effect. The notice also highlights the interaction between the Saver’s Match and Executive Order 14403, which, while largely superseded by SECURE 2.0, underscored the federal government’s push toward automatic retirement savings. Practitioners should prepare clients for the Saver’s Match by advising them to maximize contributions to eligible retirement accounts (e.g., IRAs, 401(k)s) before 2027, as the program’s refundable nature makes it far more valuable than the Saver’s Credit for lower-income taxpayers. Employers, too, must update payroll systems to handle the auto-enrollment requirements under SECURE 2.0, which will likely dovetail with the Saver’s Match’s implementation. The IRS’s request for comments in Notice 2026-48 suggests that further refinements to the program’s mechanics are possible, so practitioners should monitor proposed regulations closely to ensure compliance and optimize client benefits.

The Bulletin also addresses the simplification of rollovers under Section 324 of the SECURE 2.0 Act, which aims to reduce administrative burdens for taxpayers and plan administrators. Notice 2026-49 provides guidance on rollovers between retirement plans and IRAs, excluding IRA-to-IRA transfers, and introduces sample forms and proposed procedures designed to standardize the rollover process. The notice’s Appendix includes model forms for rollovers, which practitioners can use to ensure compliance with the new rules. The key changes under Section 324 include the elimination of the "same property" rule, meaning that any property can be rolled over (e.g., stock can be rolled over to cash), and the extension of the 60-day rollover period to 300 days for federally declared disasters. Additionally, the notice clarifies that plan loan offset rollovers now have an extended deadline to align with the tax filing deadline plus extensions. For practitioners, the most immediate impact is the need to transition clients away from manual rollovers and toward automated processes, such as the Automated Customer Account Transfer Service (ACATS), which is the industry standard for IRA transfers. ACATS transfers are faster, cheaper, and less prone to errors than manual rollovers, which often trigger 60-day rollover requirements and potential tax penalties. The IRS’s emphasis on standardized forms and procedures reflects a broader trend toward digitalization and compliance simplification, a theme that also appears in the Bulletin’s update to Rev. Proc. 2026-30, which mandates electronic submission for letter ruling requests.