In this release, the IRS outlines updates in IRB 2026-13. This article covers digital asset reporting, depreciation limits, and foreign income waivers.
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ADMINISTRATIVE
Notice 2026-4, page 726.
This notice request comments on whether the requirements that brokers currently must meet to furnish certain payee statements to their customers in an electronic format and thereafter be treated as timely furnishing these statements should be modified and, if so, what those modifications should be. This notice also requests comments on whether the Treasury Department and the IRS should modify the electronic furnishing requirements applicable to any persons other than brokers required to furnish other payee statements.
REG-105064-25, page 735.
These proposed regulations would enable brokers to furnish payee statements to their customers reflecting information reported to the IRS on Form 1099-DA, Digital Asset Proceeds From Broker Transactions (1099-DA statements) in an electronic format in lieu of on paper pursuant to an optional process for obtaining the customer’s consent. Under this process, brokers would not be required to offer customers the choice of receiving the 1099-DA statements on paper (or the ability to withdraw previously provided consents for electronic furnishing) but instead could terminate their relationship with customers that do not provide this consent. The proposed rules would, however, require brokers to meet certain enhanced electronic notice and delivery requirements and to provide customer access to the statements.
REG-117002-25, page 761.
The proposed regulations are to implement section 6434 of the Internal Revenue Code, enacted by Congress in Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act of 2025. Section 6434 authorizes the Secretary of the Treasury to make a one-time $1,000 pilot program contribution to the Trump account of an eligible child for whom a pilot program election is made. The proposed regulations provide guidance on the effects of making an election under section 6434 and the rules for the time and manner for making such election.
EMPLOYEE PLANS
REG-117270-25, page 772.
The proposed regulations provide general requirements for a Trump account under section 530A and rules for making an election to open an initial Trump account and also reserve additional sections for further guidance on Trump accounts.
INCOME TAX
REG-108921-25, page 756.
This document proposes to remove regulations identifying certain partnership related-party basis adjustment transactions and substantially similar transactions as transactions of interest, a type of reportable transaction.
Rev. Proc. 2026-15, page 729.
This revenue procedure provides: (1) two tables of limitations on depreciation deductions for owners of passenger automobiles placed in service by the taxpayer during calendar year 2026; and (2) a table of dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2026. The tables detailing these depreciation limitations and amounts used to determine lessee income inclusions reflect the automobile price inflation adjustments required by section 280F(d)(7). For purposes of this revenue procedure, the term “passenger automobiles” includes trucks and vans.
Rev. Proc. 2026-16, page 733.
Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. However, if their tax home is in a foreign country and they meet either the bona fide residence test or the physical presence test, they can choose to exclude from their income a limited amount of their foreign earned income (up to $130,000 for 2025). Both the bona fide residence test and the physical presence test contain minimum time requirements. Revenue Procedure 2026-16 provides a waiver under section 911(d)(4) for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2026-16 adds Haiti, Ukraine, Democratic Republic of the Congo, South Sudan, Iraq, Lebanon, and Mali to the list of waiver countries for tax year 2025 for which the minimum time requirements are waived.