SECTION 1. OVERVIEW

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to publish a notice of proposed rulemaking (forthcoming proposed regulations) addressing the exclusion of interest on loans secured by rural or agricultural real property under § 139L of the Internal Revenue Code (Code). ¹ Section 139L was added to the Code by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). The Treasury Department and the IRS intend to propose rules in the forthcoming proposed regulations similar to the interim guidance provided in section 3 of this notice. Taxpayers may rely on the interim guidance in section 3 of this notice in accordance with section 4 of this notice. Section 5 of this notice requests comments on issues addressed in this notice and certain additional issues, as well as other issues on which taxpayers believe guidance would be helpful.