IRS Roundup: Auto Depreciation Limits, Section 911 Relief, and a Zero-Basis Tax Court Ruling

Here's what hit the IRS guidance wire between March 3 and March 10, 2026 - courtesy of McDermott Will & Schulte's tax controversy team.

If you're in practice, these are the updates worth knowing.

Auto Depreciation Limits Updated

Revenue Procedure 2026-15 dropped on March 3, updating luxury auto depreciation limits under Section 280F for vehicles placed in service in 2026.

This includes passenger vehicles, trucks, and vans. The guidance provides separate first-year depreciation caps depending on whether bonus depreciation under Section 168(k) applies - so you'll need to check which bucket your client's vehicle falls into.

Also included: lease inclusion amounts for vehicles first leased in 2026. If you have clients buying or leasing cars this year, this is your reference doc.

Section 911 Relief for Adverse Conditions

Revenue Procedure 2026-16 (published March 4) gives relief to individuals who failed to meet Section 911(d)(1) requirements for 2025 due to adverse conditions in their country of residence.

The IRS lists countries and "date of departure on or after" thresholds - Haiti, Ukraine, and the Democratic Republic of the Congo are on the list, among others.

If you have expat clients who had to leave a foreign country mid-year due to war, civil unrest, or similar conditions, this procedure can save them from losing foreign earned income exclusion benefits.

Electronic Payee Statements: IRS Wants Comments

Notice 2026-4 (March 5) is a request for comments on whether to modify requirements for electronic furnishing of certain payee statements.

This affects brokers and potentially other furnishers. If you deal with 1099s, 1098s, or other information returns, the IRS is asking what should change about the electronic delivery rules.

Comments are open - if you have strong opinions about how these should work, now's the time to submit them.

Weekly Written Determinations

The IRS also released its weekly list of written determinations on March 5 - Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice.

If you're working on a complex issue and wondering if there's guidance out there, the weekly determinations list is worth scanning. These aren't binding precedent for anyone except the taxpayer who requested them, but they show you how the IRS is thinking about specific fact patterns.

Big Court Decision: Zero Basis on Self-Issued Notes

On March 2, the U.S. Tax Court ruled in a partnership basis case that's going to matter for anyone dealing with contributed debt.

A German parent company contributed a $610 million promissory note to a partnership after its wholly owned subsidiary elected to be disregarded for U.S. tax purposes (check-the-box election).

Because the retroactive election caused the transaction to be treated as the parent contributing its own note, the Tax Court said the note had zero basis. Why? A taxpayer incurs no "cost" in issuing its own obligation.

Result: zero basis in the partnership interest, and zero basis in the partnership's basis in the note.

If you're advising clients on partnership contributions involving debt - especially cross-border structures with check-the-box elections - this case is required reading.

What CPAs Should Do

If you have clients buying vehicles in 2026, pull Rev. Proc. 2026-15 and update your depreciation worksheets.

If you have expat clients who left adverse condition countries in 2025, check Rev. Proc. 2026-16 to see if they qualify for Section 911 relief.

If you're dealing with partnership contributions involving self-issued debt, read the Continental Grand Limited Partnership Tax Court opinion - it's going to change how you think about basis.

And if you have thoughts on electronic payee statements, submit comments on Notice 2026-4 before the deadline.

Bottom line: This was a busy week for IRS guidance. The auto depreciation limits are immediate, the Section 911 relief helps expats retroactively, and the Tax Court ruling on zero basis could affect partnership structuring going forward.