Tax Brief Issue 12: New mileage rates, late-election relief

01. Mid-Year Mileage Rates & Trump Account Gifts

• Optional standard mileage rates are revised mid-year, effective July 1, 2026, to 76 cents per mile for business and 23.5 cents per mile for medical and moving purposes.
• A new safe harbor allows certain contributions to Trump accounts to be treated as completed gifts eligible for the annual per-donee gift tax exclusion (e.g., $19,000 for 2026), thus not requiring a gift tax return if specific conditions are met.

Source: IRS Internal Revenue Bulletin · 2026-07-13

02. Late 336(e) Election Relief (Stock Sale)

• The IRS granted Section 301.9100-3 relief for a late Section 336(e) election for an S corporation stock disposition, illustrating that reasonable reliance on a qualified tax professional's error can constitute reasonable cause for extension.

Source: IRS Written Determinations · 2026-07-10

03. GST Exemption Extension Relief

• Taxpayers who missed allocating Generation-Skipping Transfer (GST) exemption due to reliance on a qualified tax professional may be granted an extension under IRC Section 2642(g) and Reg. Section 26.2642-7.
• Such allocations, if granted an extension, will be effective as of the original transfer dates based on the fair market value at that time, and must be reported on amended Forms 709.

Source: IRS Written Determinations · 2026-07-10