The IRS released its 2026 Revenue Procedures, detailing rules for requesting rulings, technical advice and related guidance.
The US Internal Revenue Service has issued Internal Revenue Bulletin 2026-01 on 29 December 2025, which includes five Revenue Procedures for 2026: letter rulings, determination letters, information letters and technical advice from the IRS.
The bulletin outlines how the IRS provides rulings and technical advice across various tax areas and identifies the Associate Chief Counsel offices responsible for specific matters, including corporate, international and exempt organisation issues.
It also explains the publication of substantive rulings to support consistent application of tax law while safeguarding taxpayer confidentiality through the removal of identifying information.
Detailed instructions are provided on how taxpayers and advisers may submit requests. These include applicable user fees, required supporting documentation and the permitted methods for electronic or physical submission to the Service.
The Revenue Procedures also clarify the legal effect and limitations of IRS rulings, noting that they may be relied on as precedent but do not carry the same authority as Treasury Regulations.
In addition, they list specific “no-rule” areas where the IRS will not issue guidance, often due to the factual nature of the issue or the existence of pending litigation.
