Rev. Proc. 2026-10: Guidance on process for requesting PLRs for consent to make retroactive QEF election under section 1295
Effective for all PLR requests received on or after January 20, 2026
The IRS today released Rev. Proc. 2026-10, providing guidance on the process for requesting private letter rulings (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) and Treas. Reg. § 1.1295-3(f).
Rev. Proc. 2026-10 is effective for all PLR requests received on or after January 20, 2026.