Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 13, 2026 – April 17, 2026.
April 13, 2026: The IRS issued Notice 2026-26, providing updated monthly interest rates for pension funding calculations, including the corporate bond yield curve, spot segment rates under § 417(e)(3), and 24-month average segment rates under § 430(h)(2). The notice also provides the 30-year Treasury rate for March 2026 (4.85%) and related weighted average rates used in determining minimum funding requirements.
April 13, 2026: The IRS issued Revenue Procedure 2026-19, providing updated domestic asset/liability percentages and investment yields used by foreign insurance companies to compute minimum effectively connected net investment income under § 842(b) for 2025. The guidance sets the domestic asset/liability percentages at 128.2% for foreign life insurers and 202.4% for foreign property and casualty insurers, with corresponding domestic investment yields of 2.1% and 2.2%, respectively.
The revenue procedure also provides instructions for calculating estimated tax and installment payments, requiring taxpayers to use these updated percentages and yields when determining minimum effectively connected net investment income and reflects data derived from 2023 tax return information.
April 13, 2026: The IRS issued Revenue Ruling 2026-8, providing updated Standard Industry Fare Level rates and the terminal charge for valuing noncommercial flights on employer-provided aircraft under § 61 and Treasury Regulation § 1.61-21(g). Starting January 1 through June 30, 2026, the ruling sets the terminal charge at $54.48 and establishes mileage rates of $0.2980 (up to 500 miles), $0.2272 (501 to 1,500 miles), and $0.2184 (more than 1,500 miles), which are used to calculate the taxable value of this fringe benefit.
April 16, 2026: The IRS issued Revenue Ruling 2026-9, providing monthly applicable federal rates (AFRs) for May 2026, including short-, mid-, and long-term rates under § 1274, as well as adjusted AFRs, § 382 rates, and low-income housing credit percentages. The ruling also sets the § 7520 rate at 5.00% for determining present value calculations.
The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice)
Recent court decision
April 15, 2026: A federal district court in Texas held that the IRS exceeded its statutory authority in designating certain micro-captive insurance arrangements as “listed transactions” under § 6707A, finding that the agency failed to demonstrate that such transactions are presumptively tax-avoidant. Relying on Loper Bright, the court emphasized that it must exercise independent judgment in determining the limits of the IRS’s statutory authority, rejecting any deference to the agency’s interpretation and focusing on whether the regulations fell within the outer bounds of Congress’s delegation. The court concluded that § 6707A requires a meaningful distinction between transactions that merely have the potential for abuse and those that are more likely than not tax-avoidant and found that the administrative record did not support the heightened standard required for listed transactions. The court therefore declared Treasury Regulation § 1.6011-10 invalid and vacated it.
However, the court upheld the IRS’s authority to classify similar arrangements as “transactions of interest” under Treasury Regulation § 1.6011-11, concluding that the IRS reasonably established its potential for tax abuse and satisfied Administrative Procedure Act requirements.
