Rev. Proc. 2026-10, page 394.

This is a revenue procedure that provides additional guidance on the process for requesting PLRs from the IRS, as generally set forth in Rev. Proc. 2025-1, for consent to make retroactive qualified electing fund (QEF) elections under section 1295(b) of the Internal Revenue Code and Treas. Reg. § 1.1295-3(f).

T.D. 10041, page 360. This document contains final regulations regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The final regulations relate to how qualified derivative payments with respect to securities lending transactions are determined and reported. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties.