Internal Revenue Bulletin 2026-31 includes important guidance for tax professionals, featuring 2027 indexing adjustments for the Premium Tax Credit, final regulations identifying certain charitable remainder annuity trust (CRAT) transactions as listed transactions, and updated reporting rules for certain life insurance contract transactions. Here are the key highlights from this week's bulletin.
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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.
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, INCOME TAX
Rev. Proc. 2026-26, page 131.
This revenue procedure provides indexing adjustments to the applicable percentage table in § 36B(b)(3)(A)(i) of the Code for taxable years beginning in calendar year 2027. This table is used to calculate an individual’s premium tax credit under § 36B. The revenue procedure also provides the indexing adjustment for the required contribution percentage in § 36B(c)(2)(C)(i)(II) for plan years beginning in calendar year 2027. This percentage is used to determine whether an individual is eligible for affordable employer-sponsored minimum essential coverage under § 36B.
TD 10051, page 118.
This document contains final regulations that identify certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as listed transactions, a type of reportable transaction. Material advisors and certain participants in these listed transactions are required to file disclosures with the IRS and will be subject to penalties for failure to disclose. The final regulations affect participants in these transactions as well as material advisors but provide that certain organizations whose only role or interest in the transaction is as a charitable remainderman will not be treated as participants in the transaction or as parties to a prohibited tax shelter transaction subject to excise taxes and disclosure requirements.
INCOME TAX
TD 10052, page 121.
This document contains final regulations providing guidance on the application of the transfer for valuable consideration rules and associated information reporting requirements for reportable policy sales of interests in life insurance contracts to exchanges of life insurance contracts qualifying for nonrecognition of gain or loss and certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations. The final regulations affect parties involved in these life insurance contract transactions, including with respect to payments of reportable death benefits.