SECTION 3. PROCEDURE

The unused housing credit carryover amount allocated from the National Pool by the Secretary to each qualified state for calendar year 2025 is as follows:

Qualified State Amount Allocated Alabama 312,546 Alaska 44,851 California 2,389,455 Connecticut 222,702 Delaware 63,744 Florida 1,416,309 Illinois 770,210 Iowa 196,428 Kentucky 278,046 Massachusetts 432,437 Michigan 614,491 Nebraska 121,527 New Mexico 129,089 New York 1,203,915 North Carolina 669,367 North Dakota 48,270 Pennsylvania 792,546 Rhode Island 67,404 South Dakota 56,033 Texas 1,896,161 Utah 212,312 Vermont 39,297 Virginia 533,941 Washington 482,250 West Virginia 107,257

Bulletin No. 2026–4 393 January 20, 2026

DRAFTING INFORMATION

The principal author of this revenue procedure is Waheed Olayan of the Office of Associate Chief Counsel (Energy, Credits and Excise Tax). For further information regarding this revenue procedure, contact Mr. Olayan at (202) 317-6239 (not a toll-free number).

Because of the timing of the publication of this revenue procedure, any amount of unused housing credit carryover published in this revenue procedure that a qualified state fails to allocate before the close of 2025 will not be considered in determining whether that state qualifies for an allocation of unused housing credit carryover for calendar year 2026.

Section 42 - Low-Income Housing Credit.

EFFECTIVE DATE

This revenue procedure is effective for allocations of housing credit dollar amounts attributable to the National Pool component of a qualified state’s housing credit ceiling for calendar year 2025.

26 CFR 1.42-14. Allocation rules for post-1989 State housing credit ceiling amounts.

Guidance is provided to state housing credit agencies of qualified states that request an allocation of unused housing credit carryover under section 42(h)(3)(D) of the Internal Revenue Code. See Rev. Proc. 2024-41.

the excess distribution rules by making a timely election under section 1295 to treat a PFIC as a QEF (a QEF election), in which case the PFIC shareholder will take into account annually its pro rata share of the ordinary earnings and net capital gain of the PFIC under section 1293.

Under section 1295(a), a PFIC will be treated as a QEF with respect to a PFIC shareholder if the shareholder makes a QEF election and the PFIC complies with the requirements prescribed by the Secretary for purposes of (i) determining the ordinary earnings and net capital gain of the PFIC and (ii) otherwise carrying out the purpose of the PFIC provisions. Section 1295(b)(1) provides that a PFIC shareholder may make a QEF election with respect to a PFIC for any taxable year of the PFIC shareholder. Once made, the election will apply to that year and to all subsequent years of the PFIC shareholder unless revoked with the consent of the Secretary. Section 1295(b) (2) prescribes the time for making the election. In general, for the QEF election to be applicable to a taxable year, the PFIC shareholder must make the election by the due date, as extended under section 6081, for the PFIC shareholder’s return for that taxable year (election due date).

If a PFIC shareholder makes a QEF election that is effective the first taxable year in which the PFIC shareholder held stock in that PFIC, the PFIC shareholder is not subject to the excess distribution rules with respect to the PFIC (such QEF, a pedigreed QEF). Further, a pedigreed QEF with respect to a PFIC shareholder

26 CFR 601.201: Rulings and determination letters (Also: Part 1, §§ 1295; 1.1295-3)