SECTION 10. REQUEST FOR

COMMENTS

.01 Comments regarding guidance pro- vided in this notice . The Treasury Department and the IRS request comments on questions arising from the interim guidance set forth in this notice. Commenters are encouraged to specify the issues on which additional guidance is needed in the forthcoming proposed regulations. In addition to general comments regarding the provisions of this notice, the Treasury Department and the IRS request comments to address the following specific questions:

(1) Allocation of basis to eligible prop- erty (section 4.08 of this notice) . What are some other examples of reasonable methods to allocate a property’s basis between eligible property and ineligible property?

(2) Manufacturing, chemical produc- tion, agricultural production, or refining (section 5 of this notice) . Are the definitions for manufacturing, chemical production, agricultural production, and refining representative of their respective industries? Should the definitions, or the examples, in section 5 of this notice be

expanded to include additional activities or examples, and if so, which activities or examples?

(3) Examples of substantial transfor- mation of property (section 5.02(9) of this notice) . What other examples of activities that are, or are not, manufacturing, production, or refining that result in substantial transformation of property comprising a qualified product would be helpful to include in the forthcoming proposed regulations?

.02 Procedures for submitting com- ments .

(1) Deadline . Written comments should be submitted by April 20, 2026. Consideration will be given, however, to any written comment submitted after April 20, 2026, if such consideration will not delay the issuance of forthcoming proposed regulations.

(2) Form and manner . The subject line for the comments should include a reference to Notice 2026-16. All commenters are strongly encouraged to submit comments electronically. However, comments may be submitted in one of two ways:

(a) Electronically via the Federal eRulemaking Portal at www.regulations. gov (type IRS-2026- 0016 in the search field on the regulations.gov homepage to find this notice and submit comments); or

(b) By mail to: Internal Revenue Service, CC:PA:LPD:PR (Notice 2026-16), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C., 20044.

(3) Publication of comments . The Treasury Department and the IRS will publish for public availability any comment submitted electronically and on paper to its public docket on regulations.gov.