Coming soon

Treasury Proposed Regulations under §25F — Coming Soon

After Notice 2025-70's comment period, Treasury will publish proposed regulations specifying donor substantiation, joint-filer cap treatment, AMT coordination, SGO certification process, and income verification.

Treasury Department / IRS · expected 2026

Proposed Regulations under §25F

Not yet published

After Notice 2025-70's comment period, Treasury will publish proposed regulations specifying donor substantiation, joint-filer cap treatment, AMT coordination, SGO certification process, and income verification.

Expected:Anticipated 2026, ahead of January 1, 2027 launch

Following IRS Notice 2025-70 (which closed for public comment on December 26, 2025), Treasury and the IRS will issue proposed regulations to implement §25F. Topics expected to be addressed include:

  • Joint-filer cap treatment ($1,700 vs. $3,400 question)
  • AMT coordination for the §25F credit
  • Donor substantiation requirements (form / acknowledgment letter)
  • State certification process for SGO lists
  • Income verification methodology for the 300% AMGI threshold
  • Operational rules for multi-state SGOs (90% spending requirement allocation)
  • Trust and estate eligibility for the credit
  • Anti-earmarking and self-dealing safeguards

This page will be updated with the verbatim regulatory text and a plain-English summary as soon as Treasury publishes the proposed regulations.

Treasury Department / IRS — anticipated 2026
Citation
Treasury Department / IRS — anticipated 2026
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SGO Software

The operating platform built for SGOs

Donor onboarding, identity verification, payment collection, scholarship awards, and per-donor §25F receipts — designed around the January 1, 2027 launch.

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