Treasury Department / IRS · expected 2026
Proposed Regulations under §25F
Not yet published
After Notice 2025-70's comment period, Treasury will publish proposed regulations specifying donor substantiation, joint-filer cap treatment, AMT coordination, SGO certification process, and income verification.
Expected:Anticipated 2026, ahead of January 1, 2027 launch
Following IRS Notice 2025-70 (which closed for public comment on December 26, 2025), Treasury and the IRS will issue proposed regulations to implement §25F. Topics expected to be addressed include:
- Joint-filer cap treatment ($1,700 vs. $3,400 question)
- AMT coordination for the §25F credit
- Donor substantiation requirements (form / acknowledgment letter)
- State certification process for SGO lists
- Income verification methodology for the 300% AMGI threshold
- Operational rules for multi-state SGOs (90% spending requirement allocation)
- Trust and estate eligibility for the credit
- Anti-earmarking and self-dealing safeguards
This page will be updated with the verbatim regulatory text and a plain-English summary as soon as Treasury publishes the proposed regulations.