SECTION 6. DRAFTING
Internal Revenue Bulletin 2025-50 · 2026-10-03 edition · updated 2026-10-04 · United States
INFORMATION
The principal author of this notice is Edward Waters of the Office of the Associate Chief Counsel (Income Tax & Accounting). However, other personnel from the Treasury Department and the IRS participated in its development. For further information regarding this notice, please contact Mr. Waters at (202) 3177009 (not a toll-free number).
December 8, 2025 778 Bulletin No. 2025–50
(c) Rural or agricultural real estate . For purposes of § 139L, § 139L(c)(3) defines the term rural or agricultural real estate as any real property which is substantially used for the production of one or more agricultural products; any real property which is substantially used in the trade or business of fishing or seafood processing; and any aquaculture facility. Such term does not include any property which is not located in a State or a possession of the United States.
(d) Aquaculture facility . Section 139L(c)(4) defines the term aquacul- ture facility to mean any land, structure, or other appurtenance that is used for aquaculture (including any hatchery, rearing pond, raceway, pen, or incubator).
.02 Effective date . Section 139L applies to taxable years ending after July 4, 2025 (that is, the date of the enactment of the OBBBA).
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