SECTION 9. APPLICABILITY DATE

AND RELIANCE

It is anticipated that the forthcoming proposed regulations will provide that rules consistent with the interim guidance provided in sections 3 through 8 of this notice apply to property the construction of which begins after January 19, 2025 (or, in the case of property described in section 4.06 of this notice, that is acquired after January 19, 2025), and which is placed in service in a taxable year beginning on or after the date the final § 168(n) regulations are published in the Federal Register . For property the construction of which begins after January 19, 2025 (or,

Bulletin No. 2026–11 695 March 9, 2026

in the case of property described in section 4.06 of this notice, that is acquired after January 19, 2025), and is placed in service in a taxable year beginning before the date the forthcoming proposed regulations are published in the Federal Register or other published guidance is issued, a taxpayer may rely on the guidance provided in sections 3 through 8 of this notice, provided that the taxpayer follows the guidance provided in sections 3 through 8 of this notice in its entirety for all QPP placed in service in such taxable years, beginning with the first taxable year with respect to which the taxpayer relies on the guidance provided in sections 3 through 8 of this notice.