The Internal Revenue Bulletin No. 2026–26, released on June 22, 2026, introduces three pivotal developments reshaping tax administration and compliance across estate planning, nonprofit governance, and renewable energy incentives.
The IRS has ruled that for purposes of computing accuracy-related penalties under IRC § 6662, a partnership is treated as an individual subject to tax for the reviewed year.
The IRS has ruled that items of income omitted from a return but adequately disclosed under IRC § 6501(e)(1)(B)(iii) are excluded from both the numerator and denominator when calculating the 25% omission threshold under IRC § 6501(e)(1).
C. § 574, which governs confidentiality in federal alternative dispute resolution (ADR) processes.
The IRS granted a 90-day extension to a taxpayer seeking to retroactively elect Interest Charge Domestic International Sales Corporation (IC-DISC) status under § 992 of the Internal Revenue Code, despite the taxpayer’s initial filing of an invalid Form 4876-A.
9100-3 of the Procedure and Administration Regulations to an estate that missed its portability election under Section 2010(c)(5)(A) of the Internal Revenue Code.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after failing to file an Electing Small Business Trust (ESBT) election under § 1361(e)(3).
7701-3, to be treated as a corporation for federal tax purposes. The taxpayer had intended to elect corporate status effective on a specified date but missed the filing deadline due to an administrative oversight. 9100-3 when taxpayers demonstrate good faith and no prejudice to the government.
A single checkbox on a taxpayer’s Form 709 nearly cost her over $5 million in lost Generation-Skipping Transfer (GST) tax exemption—but the IRS stepped in with a lifeline.
9100-3 of the Procedure and Administration Regulations. The elections were deemed effective as of Date 2, with the taxpayer receiving 120 days from the date of the PLR to file the required forms. This relief is non-precedential and applies solely to the facts presented in the ruling.
9100-3 to an estate seeking a retroactive Qualified Terminable Interest Property (QTIP) election under § 2056(b)(7), allowing the marital deduction despite a missed filing deadline.
S. S. tax purposes. S. trade or business—also prompted the IRS to decline ruling on the bank’s wholesale liabilities, instead opting for a closing agreement. S. operations, where missteps in liability allocation or recordkeeping can trigger costly audits or disallowed deductions.
The IRS has granted two non-precedential rulings (PLR-115162-25) that clarify self-dealing rules under Section 4941 for private foundations.
The IRS has ruled affirmatively in a private letter ruling (PLR-115161-25) that the estate administration exception under Treas. Reg. 4941(d)-1(b)(3) may apply to transactions involving Company Stock held in Revocable Trusts for a private foundation.
The IRS has approved two critical exceptions under § 4941 permitting transactions involving Company Stock held in revocable trusts, provided strict conditions are met.
The IRS has approved exceptions to the strict self-dealing rules under Section 4941 for transactions involving a private foundation, revocable trusts, and a closely held corporation, provided specific conditions are met.
The IRS has issued guidance clarifying when the estate administration exception under Treas. Reg. 4941(d)-1(b)(3) applies to transactions involving private foundations, revocable trusts, and estate assets.
The IRS ruled that a proposed cross-border redomiciliation qualifies as a tax-free reorganization under § 368(a)(1)(F), a provision allowing corporations to restructure without triggering gain or loss recognition. S.
The IRS granted a 120-day extension under § 2642(g) to a taxpayer who failed to allocate GST exemption to a trust transfer, retroactively effective to the original funding date.
The IRS has issued a non-precedential private letter ruling (PLR-115055-25) approving an S corporation’s use of fair value hedge accounting for sales hedges on gasoline inventory without violating the LIFO conformity requirement under Section 472(c) of the Internal Revenue Code.
The IRS has ruled that fees collected by a regulated utility under a state-mandated cost-recovery framework constitute gross income under Section 61 of the Internal Revenue Code, and are not excludable as contributions to capital under Section 118.
The IRS has approved tax treatment that treats a universal life insurance base contract and a single premium immediate annuity rider as separate contracts for federal tax purposes.
The IRS has issued a landmark ruling granting 10 specific tax rulings for a universal life insurance contract paired with an immediate annuity rider, confirming that the base insurance policy and annuity component must be treated as separate contracts for federal tax purposes.
The IRS granted a 120-day extension to allocate GST exemption to an irrevocable trust funded with $Z million in transfers, after the taxpayer’s accounting firm failed to advise on the election.
The Tax Court’s June 17, 2026 ruling in Novak v. C. Memo.
3 million tax deficiency for tax years 2015 through 2017. The IRS, acting under Section 6020(b), prepared substitutes for returns (SFRs) after Branch failed to file, estimating over $6 million in annual gross receipts for her sole proprietorship.
S. 41-4A(d)(3). The court rejected the IRS’s attempt to fully disallow the credits but also rejected the taxpayers’ argument that the Supreme Court’s 2024 decision in Loper Bright Enterprises v. Raimondo invalidated the funded research regulations under Section 41(d)(4)(H).
The IRS Bulletin No. 2026–25, released June 15, 2026, introduces four major updates reshaping tax planning for health savings accounts (HSAs), broker-dealer compliance, foreign government taxation, and energy sector incentives.
The IRS granted a 120-day extension for a late § 754 election after a State limited partnership inadvertently failed to file the election following a partner’s death. 9100-3, allowing the partnership to retroactively elect to adjust the basis of its property under § 754 of the Internal Revenue Code.
The IRS granted relief under Section 1362(f) to an LLC that inadvertently failed to qualify as an S corporation due to its operating agreement and profits interests violating the one-class-of-stock rule under Section 1361(b)(1)(D).