Highlights of Internal Revenue Bulletin 2026-37 – September 8, 2026

Highlights of Internal Revenue Bulletin 2026-37 – September 8, 2026

The IRS issued Internal Revenue Bulletin 2026-37 with proposed regulations, revenue guidance, and updated federal tax rates. Tax professionals should review these developments to stay informed about upcoming regulatory changes and compliance considerations affecting clients and businesses.

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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.

INCOME TAX 

REG 101355-26, page 247. 

These proposed regulations provide guidance on employer contributions to Trump accounts under section 128 of the Internal Revenue Code. They also provide guidance on nondiscrimination requirements for purposes of both section 128 Trump account contribution programs and section 129 dependent care assistance programs.

REG-103844-26, page 272.

The Notice of Proposed Rulemaking provides an election under which controlled foreign corporations (CFCs) would not compute or recognize foreign currency gain or loss under section 987(3), except in connection with certain inbound transactions. The proposed regulations would provide that a CFC generally does not compute or recognize section 987 gain or loss for taxable years in which the CFC exemption election is in effect. However, a CFC would be required to recognize section 987 gain or loss arising before the election is made and would be required to recognize section 987 gain in connection with certain inbound transactions.

REG-115145-25, page 298.

These proposed regulations provide for the allocation of foreign taxes of foreign corporations affected by the repeal of the one-month deferral election. These proposed regulations also provide for the disallowance of foreign tax credits on certain distributions of previously taxed earnings and profits.

Rev. Rul. 2026-17, page 247.

Federal rates; adjusted federal rates; adjusted federal longterm 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 September 2026.

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