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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

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January 7, 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.

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