Unified Agenda
Internal Revenue Service: 2026 Regulatory Agenda
Every rulemaking the IRS has on its regulatory agenda in the 2026 Unified Agenda. Proposed rules, final rules, and long-term actions, each with the agency's own summary and its latest status.
Source: the 2026 Regulatory Plan and Unified Agenda, published by OIRA on July 3, 2026 (reginfo.gov). The IRS lists 175 active actions plus 24 completed this cycle. Refreshed as the agenda changes.
What changed since the Spring 2025 agenda
Between editions, the IRS added 54 new rules, changed the stage on 71, and dropped 96 from the agenda. The official agenda only shows you today’s snapshot. We keep the history, so you can see what actually moved.
- New this edition. Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to the Refunded Portion of Certain Federal Refundable Tax Credits (entered the Long-Term stage)
- Moved. 1.355-5 Reg Amendment (Final Rule to Completed)
- Moved. Additional Guidance Under Section 199A (Proposed Rule to Long-Term)
and 218 more changes this edition, including 96 rules that dropped off the agenda entirely.
Track the IRS agenda freeSignificant, priority, and finalized rules are shown in full below. Routine actions are condensed to a line, with full summaries for every rule on the dashboard.
Slated for a final rule. Several have already published in the Federal Register, which we mark on each; the rest are still pending.
Election for Trump accounts contribution pilot program
This regulation will provide guidance regarding the effect and treatment of elections for Trump account contribution pilot program payments under section 6434. This regulation will also provide guidance on the time and manner for elections under section 6434.
Status: Proposed rule published on March 9, 2026
Independent Dispute Resolution Operations
This document finalizes rules related to certain provisions of the No Surprises Act regarding the Federal independent dispute resolution (IDR) process, which was established as part of the Consolidated Appropriations Act, 2021 (CAA). This rule sets forth new requirements relating to the disclosure of information that group health plans and health insurance issuers offering group or individual health insurance coverage must include along with the initial payment or notice of denial of payment for certain items and services subject to the surprise billing protections in the No Surprises Act. This rule also requires plans and issuers to communicate information by using claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs), as specified in guidance, when providing any paper or electronic remittance advice to an entity that does not have a contractual relationship with the plan or issuer. This document also amends certain requirements related to the open negotiation period preceding the Federal IDR process, the initiation of the Federal IDR process, the Federal IDR dispute eligibility review, and the payment and collection of administrative fees and certified IDR entity fees. This document also defines bundled payment arrangements, amends requirements related to batched items and services, and amends the rules for extensions of timeframes due to extenuating circumstances. Additionally, this document requires plans and issuers to register in the Federal IDR portal.
Status: Final rule published in the Federal Register on June 4, 2026
List of Occupations Traditionally and Customarily Receiving Tips
These amendments to the Treasury regulations provide a list of occupations which traditionally and customarily received tips on or before December 31, 2024. In section 70201(h) of the OBBBA Congress instructed the IRS to issue regulations under section 224 of the Code, which was created by the OBBBA.
Status: Final rule published in the Federal Register on April 13, 2026
Section 45Z Clean Fuel Production Credit
This Notice of Proposed Rulemaking (NPRM) would provide guidance and address public feedback regarding the implementation of 26 U.S.C. 45Z, including the calculation of emissions factors for transportation fuel, the determination of clean fuel production credits under 26 U.S.C. 45Z, and registration as a producer of clean fuel under 26 U.S.C. 4101 (as required by 26 U.S.C. 45Z(f)(1)(A)(i)(I)). The NPRM would implement 26 U.S.C. 45Z as modified by the One, Big, Beautiful Bill Act ( Public Law No. 119-21 , 139 Stat. 72 (2025)). The NPRM would also support Unleashing American Energy (EO 14154) by incentivizing the domestic production of clean transportation fuel. Notice 2025-10 (2025-6 I.R.B. 682), which is available at IRS.gov, contains draft intended rules for the 26 U.S.C. 45Z credit and for 26 U.S.C. 4101 registration under 26 U.S.C. 45Z, and requests public feedback. Notice 2025-11 (2025-6I.R.B.704), which is available at IRS.gov, contains the initial emissions rate table, explains how to calculate emissions rates for the 26 U.S.C. 45Z credit, and requests public feedback. These notices were published in early 2025 to meet the statutory deadline of January 1, 2025. However, the rules need to be further formalized in an NPRM and then finalized to provide further guidance and clarity for taxpayers.
Status: Proposed rule published on May 8, 2026
Additional Guidance for Reporting and Transfer for Value Rules Relating to Life Insurance Transactions
The final regulations will amend regulations under sections 101 and 6050Y (TD 9879) published in the Federal Register (84 FR 58460) on October 31, 2019 (2019 final regulations). The 2019 final regulations provide guidance on transfers for value and reportable policy sales of interests in life insurance contracts and payments of reportable death benefits and associated information reporting requirements. In response to public inquiries on certain aspects of the 2019 final regulations, the final regulations will provide relief for (1) certain exchanges of life insurance contracts qualifying for nonrecognition of gain or loss under section 1035 and (2) certain acquisitions of interests in life insurance contracts in transactions qualifying as corporate reorganizations.
Status: Final rule published in the Federal Register on July 9, 2026
Amendment of Consolidated Returns Regulations to Reflect Current Law
This document contains regulations under section 1502 of the Internal Revenue Code (Code). The regulations update the regulations under section 1502 by revising and removing text that has become outdated as a result of changes in the law. The regulations affect corporations filing consolidated returns. The proposed regulations withdrew or partially withdrew numerous notices of proposed rulemaking. The IRS accepted public comments from August 7, 2023, to November 6, 2023. The IRS reopened the comment period on December 6, 2023, and accepted public comments until February 5, 2024. Final regulations were published on December 30, 2024. In conjunction with the final regulations, the Treasury Department and the IRS published additional proposed regulations that would clarify the timing of a single basis adjustment required by statute.
Status: Final rule published in the Federal Register on December 30, 2024
Certain Dual Consolidated Loss Rules
The regulation provides rules regarding the application of the dual consolidated loss rules and the treatment of certain disregarded payments.
Status: Final rule published in the Federal Register on January 14, 2025
Enrolled Agent Special Enrollment Examination User Fee Update
These regulations will update the user fee for each part of the special enrollment examination for enrolled agents.
Status: Final rule published in the Federal Register on April 20, 2026
Returns Relating to Sales or Exchanges of Certain Partnership Interests.
On November 30, 2020, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) published T.D. 9926, 85 FR 76910, which amended 1.6050K-1(c)(2) to require a partnership to furnish to a transferor partner the information necessary for the transferor to make the transferor partner's required statement in 1.751-1(a)(3). Among other items, 1.751-1(a)(3) requires a transferor partner in a 751(a) exchange to submit with the transferor partner's income tax return a statement setting forth the amount of gain or loss attributable to 751 property. Section 6050K(b) requires that partnerships send the information required, including required by regulation, to the transferor and transferee by January 31 of the year following the year of the transfer. Section 6722 provides penalties for failure to provide payee statements. In October 2023, the IRS released a revised version of Form 8308. Consistent with the requirements in 1.6050K-1(c)(2), Part IV of the October 2023 Form 8308 requires a partnership to report, among other items, the partnership's deemed sale 751 gain or loss, deemed sale 1(h)(5) collectibles gain, and deemed sale 1(h)(6) unrecaptured 1250 gain, as well as the transferor partner's share of such amounts. This information was also required on the October 2024 version of Form 8308. Since the issuance of the October 2023 Form 8308, the Treasury Department and the IRS received comments that many partnerships will be unable to furnish the information required in Part IV of the Form 8308 to transferors and transferees by the January 31 due date, because, in many cases, partnerships will not have all of the information required by Part IV of the Form 8308 by January 31 of the year following the calendar year in which the 751(a) exchange occurred. On January 11, 2024, the IRS released Notice 2024-19, which provided relief from penalties under 6722 for partnerships with 751(a) exchanges occurring during calendar year 2023 if partnerships provided Parts I through III of the form to the transferors and transferees by January 31 and completed Part IV to file with the partnerships return by the return deadline. On December 13, 2024, the IRS released Notice 2025-2, which provided the same relief for calendar year 2024. On February 19, 2025, the President issued Executive Order 14219, Ensuring Lawful Governance and Implementing the President's Department of Government Efficiency Deregulatory Initiative (Executive Order 14219). Executive Order 14219 directs agencies to initiate a review process for the identification and removal of certain regulations and other guidance that meet any of the factors set forth in Executive Order 14219. Consistent with the review required by Executive Order 14219, the Treasury Department and the IRS have identified 1.6050K-1(c)(2) as creating an undue burden by requiring the information required in Part IV of the Form 8308 be provided to transferors and transferees by January 31. These proposed regulations withdraw the regulations under 1.6050K-1(c)(2). These regulations affect partnerships and their partners.
Status: Final rule published in the Federal Register on May 20, 2026
Revising Qualified Domestic Trust Regulations under Section 2056A to Update Outdated References and Procedures
The proposed regulation contains proposed amendments to the regulations related to the requirements for a Qualified Domestic Trust (QDOT). The proposed regulation replaces out-of-date information and obsolete procedures found in the current regulations. The proposed regulation affects taxable estates that may, by use of a QDOT, qualify for an estate tax marital deduction for property passing from a deceased taxpayer to a surviving spouse who is not a United States citizen.
Status: Final rule published in the Federal Register on July 10, 2026
Taxability of Tribally Chartered Corporations
The proposed regulations would provide guidance on the taxability of tribally chartered corporations and requirements that a tribally chartered corporation must satisfy to share the tax status of the tribe.
Status: Final rule published in the Federal Register on December 16, 2025
Other actions in this stage
Rules open for, or headed toward, public comment.
Increase in Threshold for Requiring Information Reporting with Respect to Certain Payees
Updates regulations affected by the increase codified in the One, Big, Beautiful, Bill Act to the reporting threshold in section 6041.
Status: Proposed rule published on July 2, 2026
Requirements Related to Advanced Explanation of Benefits and Other Provisions Under the Consolidated Appropriations Act, 2021
This proposed rule would implement section 9816 of the Internal Revenue Code of 1986 (Code), section 716 of the Employee Retirement Income Security Act of 1974 (ERISA), and section 2799A-1 of the Public Health Service (PHS Act), as directed by section 111 of the No Surprises Act (NSA); and may include other provisions under the Consolidated Appropriations Act, 2021.
Status: Proposed rule published on September 16, 2022
Trump accounts under section 530A
These proposed regulations would provide guidance under sections 530A and 128 of the Internal Revenue Code (added by section 70204 of the OBBBA) relating to Trump accounts and Trump account contribution programs. The guidance will address multiple topics, including: (1) the requirements for Trump accounts; (2) the treatment of contributions (including qualified general contributions and section 128 employer contributions) to, and distributions from, a Trump account; (3) reporting by trustees of Trump accounts; and (4) interaction with the requirements of section 408.
Status: Proposed rule published on June 5, 2026
Withdrawal of TD 10028, Treas. Reg. 1.6011-18, Regarding Certain PS Related-Party Basis Adj Transactions and TOI
The proposed regulations remove final regulations (1.6011-18), which identify certain partnership related-party basis adjustment transactions and substantially similar transactions as transactions of interest, a type of reportable transaction.
Status: Proposed rule published on March 6, 2026
Section 6435 Dyed Fuel
26 U.S.C. 6435 provides for a refund of 26 U.S.C. 4081 tax paid on eligible previously taxed dyed diesel fuel and dyed kerosene. A Notice of Proposed Rulemaking will provide guidance regarding the implementation of 26 U.S.C. 6435, including who may make a claim for refund and how to qualify for a refund under 26 U.S.C. 6435. These proposed regulations for 26 U.S.C. 6435 will also be issued as Temporary Regulations to provide authority for the IRS and taxpayers to rely on.
Status: Final rule published in the Federal Register on May 1, 2026
Other actions in this stage
Early-stage actions: reviews and advance notices that come before a formal proposal.
On the agenda, but not expected to move within the next 12 months.
Charitable Remainder Annuity Trust Listed Transaction
This document contains additions to 26 CFR part 1 (Income Tax Regulations) under section 6011 of the Internal Revenue Code (Code). The additions identify certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as listed transactions for purposes of Treas. Reg. 1.6011-4 and sections 6111 and 6112.
Status: Final rule published in the Federal Register on July 9, 2026
Cost Sharing Under the Affordable Care Act
The proposed rule would amend regulations implementing the Affordable Care Act's provisions related cost sharing protections. This proposed rule would address the applicability of drug manufacturer support to the annual limitation on cost sharing for group and individual coverage.
Agenda status: NPRM (planned)
Other actions in this stage
Actions the agency reports as completed this cycle. The official agenda rule list files these separately from the active pipeline.
SECURE 2.0 Act Updates to Catch-up Contribution Rules Under Section 414(v)
These final regulations implement the changes to section 414(v) made by sections 109, 117, and 603 of the SECURE 2.0 Act. (Pub. L. 117-328, 136 Stat. 4459 (2022)). An NPRM was published in the Federal Register on January 13, 2025. Treasury and the IRS received comments on the NPRM, and a public hearing was held on April 7, 2025.
Status: Final rule published in the Federal Register on September 16, 2025
Amendments to the Regulations for Continuing Education Requirements of the Joint Board for the Enrollment of Actuaries
This document contains regulations relating to the renewal of membership of the Joint Board for the Enrollment of Actuaries. The regulations are being amended in order to remove the physical presence requirement for formal programs for continuing education, and to modify the additional continuing education requirement for enrolled actuaries who return to active enrollment from inactive status. Treasury and the IRS received comments on the NPRM.
Status: Final rule published in the Federal Register on August 19, 2025
Base erosion and anti-abuse tax
These regulations provide guidance under section 59A regarding the base erosion and anti-abuse tax, including guidance regarding reporting of qualified derivatives payments made with respect to securities lending transactions.
Status: Final rule published in the Federal Register on December 18, 2025
Estate Tax Closing Letter User Fee Update
This regulation will update the user fee for requesting the issuance of IRS Letter 627, also referred to as an estate tax closing letter.
Status: Final rule published in the Federal Register on December 1, 2025
Estate Tax Closing Letter User Fee Update
This regulation will update the user fee for requesting the issuance of IRS Letter 627, also referred to as an estate tax closing letter.
Status: Final rule published in the Federal Register on December 1, 2025
Excise Tax on Repurchase of Corporate Stock
These regulations will provide guidance concerning section 4501 of the Internal Revenue Code of 1986, which imposes an excise tax on certain repurchases of corporate stock. The IRS accepted public comments from April 12, 2024, to June 11, 2024.The IRS held a public hearing on August 27, 2024, at which representatives of three organizations spoke.
Status: Final rule published in the Federal Register on February 11, 2026
Guidance Regarding the Determination of Built-In Gains and Losses
These proposed regulations address built in gains and losses in a loss corporation. The IRS accepted public comments on the proposed regulations from September 10, 2019 to November 12, 2019. In response to comments received, the IRS revised portions of the proposed regulations and accepted further public comments from January 14, 2020 to March 16, 2020. The proposed regulations were withdrawn July 2, 2025.
Status: Final rule published in the Federal Register on September 14, 2020
Income of Foreign Governments and International Organizations
These regulations will provide rules relating to the taxation of the income of foreign governments from investments in the United States. In particular, these regulations will provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity.
Status: Final rule published in the Federal Register on December 15, 2025
Indian General Welfare Benefits under Section 139E
Section 139E of the Internal Revenue Code provides an exclusion from gross income for the value of any Indian general welfare benefit. An Indian general welfare benefit includes payments made or services provided to or on behalf of a member of an Indian tribe (or any spouse or dependent of such member) under an Indian tribal government program. These regulations would provide guidance under section 139E.
Status: Final rule published in the Federal Register on January 16, 2026
Interest Capitalization Requirements for Improvements to Designated Property
The proposed regulations modify the interest capitalization requirements relating to improvements made to designated property. Specifically, the proposed regulations clarify the definition of an improvement and remove the associated property rule and similar rules from the regulations. The proposed regulations follow the United States Court of Appeals for the Federal Circuit's rationale and holding in Dominion Resources, Inc. v. United States, 681 F.3d.1313 (Fed. Cir. 2012). The IRS and Treasury solicited and received public comments on the proposed rule and are reviewing and considering those comments, to include those submitted after the comment period closed.
Status: Final rule published in the Federal Register on October 2, 2025
Modification of Regulations Under Section 987 on Income and Currency Gain or Loss With Respect to a Section 987 Qualified Business Unit
This document will finalize proposed regulations that simplify the rules dealing with the determination and translation of the taxable income or loss of a taxpayer with respect to a qualified business unit subject to section 987, as well as the timing, amount, character, and source of any section 987 currency gain or loss.
Status: Final rule published in the Federal Register on January 17, 2025
Preparer Tax Identification Number (PTIN) User Fee Update
This regulation will update user fees related to applications for or renewals of preparer tax identification numbers by tax return preparers.
Status: Final rule published in the Federal Register on September 30, 2025
Related-Party Partnership Basis Adjustment Transactions as Transactions of Interest
Proposed regulations to remove a final rule that identifies certain transactions among related parties involving partnership basis adjustments resulting from nonrecognition transfers as transactions of interest under section 26 CFR 6011.
Status: Final rule published in the Federal Register on January 14, 2025
Section 42, Average Income Test Procedures
The final regulations provide guidance relating to the average income test under section 42(g)(1)(C) of the Internal Revenue Code. If a building is part of a residential rental project that satisfies this test, the building may be eligible to earn low-income housing credits. These final regulations affect owners of low-income housing projects, tenants in those projects, and State or local housing credit agencies that administer eligibility for low-income housing credits. These final regulations concern the record keeping and reporting requirements for the average income test under section 42(g)(1)(C).
Status: Final rule published in the Federal Register on September 30, 2025
Substantiation Requirements and Qualified Non-Personal Use Vehicles
Final regulations relating to qualified non personal use vehicles as defined in section 274(i) of the Internal Revenue Code. Qualified non personal use vehicles are excepted from the substantiation requirements of section 274(d) that apply to listed property as defined in section 280F(d)(4). These proposed regulations add unmarked service vehicles used by firefighters or members of a rescue squad or ambulance crew as a new type of qualified non personal use vehicle.
Status: Final rule published in the Federal Register on March 20, 2026
Treatment of Income From Indian Fishing Rights-Related Activity as Compensation
These final regulations provide that amounts paid to an Indian tribe member as remuneration for services performed in a fishing rights-related activity (as defined in section 7873(b)(1)) may be treated as compensation for purposes of applying the limits on qualified plan benefits and contributors imposed by section 415, even though those amounts are not subject to income tax under section 7873(a)(1). Treasury and the IRS received comments on the NPRM, and consulted with Tribes on December 17, 2013, and on August 22, 2024.
Status: Final rule published in the Federal Register on May 4, 2026
Other actions in this stage
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Create a free accountCompiled from the 2026 Regulatory Plan and Unified Agenda (reginfo.gov), cross-referenced against Federal Register publications. Regulation Roundup tracks all 199 IRS actions and refreshes as the agenda changes.