Highlights of Internal Revenue Bulletin 2026-3– 1/12/2026

Highlights of Internal Revenue Bulletin 2026-3– 1/12/2026

Internal Revenue Bulletin 2026-03 details proposed updates to DOJ and IRS contact procedures, foreign government investment rules, federal rate tables, and withdrawn innocent spouse regulations.

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The Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.

ADMINISTRATIVE 

REG-110519-25, page 353. 

The proposed regulations would update points of contact within the Department of Justice and the IRS. The proposed regulations are necessary to reflect a reorganization within the Department of Justice to identify new points of contact for matters involving the internal revenue laws. The proposed regulations would also update points of contact at the IRS for administrative claim submissions from taxpayers seeking civil damages for certain unauthorized collection actions or awards of administrative costs with respect to certain administrative proceedings.

REG-134219-08; REG-13225 1-11, page 358.

This document withdraws two notices of proposed rulemaking regarding innocent spouse relief.

INCOME TAX 

REG-101952-24, page 349. 

These proposed regulations relate to the taxation of the income of foreign governments from investments in the United States. In particular, these proposed regulations provide guidance for determining when an acquisition of debt by a foreign government is considered to be commercial activity, and when a foreign government has effective control of an entity engaged in commercial activity. These proposed regulations will affect foreign governments that derive income from sources within the United States.

Rev. Rul. 2026-2, page 342. 

Federal rates; adjusted federal rates; adjusted federal long term rate, and the long-term tax-exempt rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for January 2026.

T.D. 10042, page 320. 

These final regulations relate to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States.

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