Refundable credit certification and all-zero 1065s

01. Refundable credit citizenship self-certification rules

• Under proposed regulations, taxpayers claiming the refundable portion of the EITC, CTC, AOTC, or Adoption Tax Credit must self-certify their status as a U.S. citizen, national, or qualified alien on their tax return.
• For married couples filing jointly, the proposed rules allow the full refundable portion of these credits to be claimed if only one spouse meets the U.S. citizen, national, or qualified alien requirement.

Source: Federal Register - IRS · 2026-08-20

02. Saver's Match replaces credit in 2027

• For taxable years beginning after December 31, 2026, the Saver's Credit will be replaced by Saver's Match contributions of up to $1,000 paid directly by the Treasury into an eligible individual's retirement account.
• Effective September 4, 2026, all requests for Employee Plans letter rulings and nonbank trustee approval letters must be submitted electronically via pay.gov using Form 15662.

Source: IRS Internal Revenue Bulletin · 2026-08-24

03. Invalidity of all-zero Form 1065 returns

• An initial Form 1065 partnership return containing all zeros is generally considered invalid under the Beard test for failing to provide sufficient data to calculate tax.
• An all-zero return may only be considered valid if it accurately reflects the taxpayer's actual economic activity for the period.

Source: IRS Written Determinations · 2026-08-21

04. BBA push-out PDF format requirements

• Partnership push-out election submissions (Forms 8985 and 8986) must be filed in original, fillable PDF format and will be formally rejected if printed and scanned.
• Section 9100 relief is not available for rejected BBA push-out packages; partnerships must instead rely on IRS discretion to accept corrected statements under Treas. Reg. 301.6226-2(d)(3).

Source: IRS Written Determinations · 2026-08-21