Treasury and IRS Attack Investment Fund Tax Strategies, Effective Immediately
Notice 2026-62 and Rev. Rul. 2026-20, issued September 28, 2026, target fast-growing fund structures, and the revenue ruling applies at once, so fund counsel and LP clients should check existing positions now.
On September 28, 2026, the Treasury Department and the IRS issued Notice 2026-62 and Rev. Rul. 2026-20, focusing on a set of investment fund tax strategies that have grown quickly in recent years. According to the Venable summary, the revenue ruling reaches transactions immediately rather than applying only prospectively, a point that matters for clients already holding positions entered into under the older treatment.
Why sophisticated counsel cares: a revenue rule that lands with immediate effect can narrow or eliminate a position that funds, family offices, and institutional LPs treated as settled, and it may cut across structures rather than address a single transaction type. Advisers should expect questions about effective-date mechanics, grandfathering, and any administrative or legislative relief, none of which is confirmed in the available reporting.
Concrete next steps: inventory which targeted strategies the firm or its clients still use; read the full text of both the notice and the revenue ruling rather than commentary; and watch for follow-on guidance, transition rules, or IRS announcements clarifying scope, since immediate application can affect open tax years. This summary rests on a single secondary source; the specific holdings and strategies covered are unverified here.