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opportunity fund under § 6039K is $510 per day with a maximum penalty of $10,000 per return ($51,000 if the gross assets of the fund are greater than $10,230,000). If the failure to file in the time and manner prescribed is due to intentional disregard, then the penalty is $2,550 per day with a maximum penalty is $51,000 per return ($255,000 if the gross assets of the fund are greater than $10,230,000). .60 Revocation or Denial of Passport in Case of Certain Tax Delinquencies. For calendar year 2026, the amount of a serious delinquent tax debt under § 7345 is $66,000. .61 Attorney Fee Awards. For fees incurred in calendar year 2026, the attorney fee award limitation under § 7430(c)(1)(B)(iii) is $260 per hour. .62 Periodic Payments Received Under Qualified Long-Term Care Insurance Contracts or Under Certain Life Insurance Contracts. For calendar year 2026, the stated dollar amount of the per diem limitation under § 7702B(d)(4), regarding periodic payments received under a qualified long-term care insurance contract or periodic payments received under a life insurance contract that are treated as paid by reason of the death of a chronically ill individual, is $430. .63 Qualified Small Employer Health Reimbursement Arrangement. For taxable years beginning in 2026, to qualify as a qualified small employer health reimbursement arrangement under § 9831(d), the arrangement must provide that the total amount of payments and reimbursements for any year cannot exceed $6,450 ($13,100 for family coverage).

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opportunity fund under § 6039K is $510 per day with a maximum penalty of $10,000 per return ($51,000 if the gross assets of the fund are greater than $10,230,000). If the failure to file in the time and manner prescribed is due to intentional disregard, then the penalty is $2,550 per day with a maximum penalty is $51,000 per return ($255,000 if the gross assets of the fund are greater than $10,230,000). .60 Revocation or Denial of Passport in Case of Certain Tax Delinquencies. For calendar year 2026, the amount of a serious delinquent tax debt under § 7345 is $66,000. .61 Attorney Fee Awards. For fees incurred in calendar year 2026, the attorney fee award limitation under § 7430(c)(1)(B)(iii) is $260 per hour. .62 Periodic Payments Received Under Qualified Long-Term Care Insurance Contracts or Under Certain Life Insurance Contracts. For calendar year 2026, the stated dollar amount of the per diem limitation under § 7702B(d)(4), regarding periodic payments received under a qualified long-term care insurance contract or periodic payments received under a life insurance contract that are treated as paid by reason of the death of a chronically ill individual, is $430. .63 Qualified Small Employer Health Reimbursement Arrangement. For taxable years beginning in 2026, to qualify as a qualified small employer health reimbursement arrangement under § 9831(d), the arrangement must provide that the total amount of payments and reimbursements for any year cannot exceed $6,450 ($13,100 for family coverage).