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Notice 2025-70

SECTION 3. INTERIM GUIDANCE

Internal Revenue Bulletin 2025-50 · 2026-10-03 edition · updated 2026-10-04 · United States

REGARDING THE APPLICATION OF § 139L

.01 Purpose of this notice . The Treasury Department and the IRS are issuing this notice to provide interim guidance regarding the application of § 139L prior to the publication of the forthcoming proposed regulations.

.02 Defined terms . Any term not defined in this notice has the meaning provided in § 139L. For purposes of this notice:

(1) Interest received . The term inter- est received means the interest, including amounts treated as interest under the Code, that is includible in gross income by a qualified lender. For purposes of the preceding sentence, the amount of interest includible in gross income by a qualified lender is determined without regard to § 139L, and the time at which interest is includible in gross income is determined under the qualified lender’s overall method of accounting (for example, the cash receipts and disbursements method of accounting or an accrual method of accounting) or, if applicable, under a special method of accounting (for example, § 1272 for original issue discount).

(2) Pre-enactment loan . The term pre-enactment loan means any debt

Interim Guidance Regarding Interest on Loans Secured by Rural or Agricultural Real Property under Section 139L of the Internal Revenue Code

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▸Contents — Internal Revenue Bulletin 2025-50

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