29, 2026) The Department of the Treasury and the Internal Revenue Service have issued proposed regulations (REG-117095-25) implementing Internal Revenue Code (IRC) Section 1062. This statutory provision was enacted by Section 70437 of Public Law 119-21, 139 Stat.
29, 2026) The Department of the Treasury and the Internal Revenue Service have issued proposed regulations (REG-117095-25) implementing Internal Revenue Code (IRC) Section 1062.
This statutory provision was enacted by Section 70437 of Public Law 119-21, 139 Stat.
72, 248–250 (July 4, 2025), commonly referred to as the One, Big, Beautiful Bill Act (OBBBA).
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29, 2026) The Department of the Treasury and the Internal Revenue Service have issued proposed regulations (REG-117095-25) implementing Internal Revenue Code (IRC) Section 1062. This statutory provision was enacted by Section 70437 of Public Law 119-21, 139 Stat. 72, 248–250 (July 4, 2025), commonly referred to as the One, Big, Beautiful Bill Act (OBBBA).
The primary legislative purpose underlying Section 1062 is to facilitate the transition of agricultural real property to active, younger generations of farmers by easing the immediate capital gains tax burden associated with outright sales of farmland. Department promulgated these proposed regulations pursuant to its general rulemaking authority under Section 7805(a), as well as specific statutory mandates under Section 1062(c)(2) (governing pass-through entity elections) and Section 1502 (governing consolidated corporate groups).
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