26 CFR 601.601: Rules and regulations.

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Part III
Administrative, Procedural, and Miscellaneous

26 CFR 601.601: Rules and regulations.
(Also Part I, § 25F.)

Rev. Proc. 2026-6

SECTION 1. PURPOSE
This revenue procedure provides the exclusive procedure for a State 1 to make an
election to be a “covered state”2 prior to identifying scholarship granting organizations
(SGOs) in the State in accordance with § 25F(g) of the Internal Revenue Code (Code)3
(Advance Election). Making an Advance Election allows a State to inform potential
SGOs of a State's participation under section 25F before submitting its SGO list, giving
1 For purposes of this notice, the term “State” means one of the 50 States or the District of Columbia.
2 Section 25F(c)(1), as added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly
known as the One, Big, Beautiful Bill Act, defines a “covered state” as one of the 50 States, or the District
of Columbia, that, for a particular calendar year, both voluntarily elects to participate under § 25F and
identifies the scholarship granting organizations in the State, in accordance with § 25F(g).
3 Unless otherwise provided, all "section" or "§" references are to sections of the Code.

-2SGOs additional time to prepare for the commencement of this new credit in 2027.
SECTION 2. BACKGROUND
.01 Overview of § 25F Credit. Section 25F provides a nonrefundable income tax
credit (§ 25F credit) allowable to a taxpayer for qualified contributions to an SGO made
by an individual who is a citizen or resident of the United States (within the meaning of
§ 7701(a)(9)). Section 25F(c)(3) defines a “qualified contribution” as a charitable
contribution of cash to an SGO that uses the contribution to fund scholarships for
eligible students (as defined in § 25F(c)(2)) solely within the State in which the
organization is listed pursuant to § 25F(g). In order for a contribution made by a
taxpayer to an SGO in a State to be a qualified contribution eligible for a § 25F credit, a
State must have voluntarily made an election to participate under § 25F and must have
identified the SGO as one that satisfies the requirements of § 25F(c)(5) for the
applicable calendar year in accordance with § 25F(g).
.02 Statutory Requirements for Elections to Participate under § 25F. Section
25F(g)(1) provides that a State that voluntarily makes an election to participate under
§ 25F must provide to the Secretary of the Treasury or the Secretary’s delegate a list of
the SGOs that meet the requirements described in § 25F(c)(5) and are located in the
State (State SGO list). The State SGO list must be submitted by January 1 of the
calendar year for which the election to participate under § 25F is being made (or, with
respect to calendar year 2027, as early as practicable). Section 25F(g)(2) provides that
each State SGO list must include a certification that the individual, agency, or entity
submitting such list on behalf of the State has the authority to perform this function. See
sections 2.04 and 3 of Notice 2025-70, 2025-50 I.R.B. 773 (December 8, 2025), for

-3additional information and a request for comments regarding State SGO lists and the
certifications necessary for elections to participate under § 25F.
.03 Future guidance. The Department of the Treasury (Treasury Department) and
the Internal Revenue Service (IRS) intend to publish future guidance under § 25F(g) on
how a State submits its State SGO list with all required certifications. The future
guidance will provide that any State making an Advance Election will be required to
perfect its election by submitting its State SGO list in accordance with such guidance.
Future guidance also will address how to make an election to participate under § 25F
for calendar year 2027 at the same time the State submits the State SGO list, and how
to make elections (including Advance Elections) to participate under § 25F for
subsequent calendar years.
SECTION 3. SCOPE
.01 Advance Elections. This revenue procedure applies to States that choose to
make an Advance Election for calendar year 2027. Section 4 of this revenue procedure
provides the exclusive procedure for a State to make an Advance Election for calendar
year 2027.
.02 Perfection of Advance Election. As the Treasury Department and the IRS intend
to specify in future guidance, each State making an Advance Election for calendar year
2027 will need to perfect its election by submitting its State SGO list, along with all
required information and certifications, before the final date on which the State is
permitted to submit the State SGO list (as will be specified in future guidance).
Because a State that makes an Advance Election is required by § 25F(g) to provide its
State SGO list as part of its election, a failure to submit the list by the deadline would

-4not meet the statutory requirements, and, as a result, no organization in that State
would qualify as an SGO under § 25F for calendar year 2027.
SECTION 4. PROCEDURE FOR MAKING ADVANCE ELECTION FOR 2027
.01 Submission of Advance Election. If a State chooses to make an Advance
Election for calendar year 2027, the State must submit Form 15714, Advance Election
to Participate Under Section 25F for 2027, in accordance with this section 4 and the
Form 15714 instructions, on or after January 1, 2026, and before the final date on which
the State is permitted to submit the State SGO list (as will be specified in future
guidance). Form 15714, including instructions for its submission, are available at
www.irs.gov/pub/irs-pdf/f15714.pdf. No alternative method of making an Advance
Election, and no alteration of Form 15714, will be accepted for calendar year 2027. The
IRS will acknowledge or otherwise confirm receipt of a State’s Advance Election
submitted in accordance with this section 4.
.02 No Inclusion of Other Attachments or SGO List. Any State SGO list (or other
information or attachments) submitted with Form 15714 will not be processed by the
IRS and will need to be resubmitted in accordance with the procedures for submitting
State SGO lists as specified in future guidance.
.03 No Subsequent Advance Election Submissions. Once a State’s Advance
Election for calendar year 2027 has been made, the only subsequent submission that
will be processed by the Treasury Department and the IRS is the submission of the
State SGO list (including all required certifications).

-5SECTION 5. EFFECTIVE DATE
This revenue procedure is effective as of January 1, 2026. No Advance Election for
calendar year 2027 may be submitted to the IRS before January 1, 2026, or after the
day before the final date on which the State is permitted to submit the State SGO list (as
will be specified in future guidance).
SECTION 6. PAPERWORK REDUCTION ACT
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) generally
requires that a Federal agency obtain the approval of the Office of Management and
Budget (OMB) before collecting information from the public, whether such collection of
information is mandatory, voluntary, or required to obtain or retain a benefit. An agency
may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a valid control number assigned by the OMB.
Section 4 of this revenue procedure sets forth collections of information to be
provided with Form 15714, including information related to an Advance Election. The
collections will be used by the IRS for tax administration purposes. The respondents
are States that voluntarily elect, on or after January 1, 2026, to participate under § 25F
for the following calendar year in advance of perfecting the election by providing the
State SGO list, as required under § 25F(g)(1).
Estimated number of respondents: 51 respondents.
Estimated number of responses: 51 responses.
Estimated frequency of responses: Annually.
Estimated average time per response: 0.72 hours.
Estimated total annual burden: 37 hours.

-6Books or records relating to a collection of information must be retained as long as
their contents may become material in the administration of any internal revenue law.
The collection of information contained in this notice has been submitted to the OMB
under control number 1545-2335.
SECTION 7. DRAFTING INFORMATION
The principal author of this notice is Edward Waters of the Office of the Associate
Chief Counsel (Income Tax & Accounting). However, other personnel from the Treasury
Department and the IRS participated in its development. For further information
regarding this notice, please contact Mr. Waters at (202) 317-7009 (not a toll-free call).