Data / Federal rules / 2026-18645
Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income
The Internal Revenue Service published this proposed rule in the Federal Register on September 11, 2026.
SpecStream is the live web data engine for teams and agents. It reads every rule and proposed rule in the Federal Register each morning, and this page is that reading. Name your industry once and new rules, comment deadlines and effective dates arrive in your sheet, CRM, Slack or agent as they are published.
What the agency says
This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.
Key facts
- Document number
- 2026-18645
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- September 11, 2026
- Dates
- Written or electronic comments and requests for a public hearing must be received by November 10, 2026.
- Docket
- REG-117273-25
- Regulation ID (RIN)
- 1545-BR90
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 10
Other documents from the Internal Revenue Service
| Document | Type | Published |
|---|---|---|
| Guidance Under Section 355 Concerning Device and Active Trade or Business; Partial Withdrawal 2026-21568 | Proposed rule | Oct 21 |
| Regulations Regarding Payment of Tax by Commercially Acceptable Means 2026-21267 | Final rule | Oct 19 |
| Non-Applicability of Section 357(c) to Consolidated Groups 2026-21253 | Final rule | Oct 16 |
| Premium Tax Credit 2026-21056 | Proposed rule | Oct 15 |
| Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion of Certain Federal Refundable Tax Credits; Hearing Cancellation 2026-20790 | Proposed rule | Oct 9 |
| Transparency in Coverage 2026-20447 · significant | Final rule | Oct 6 |
| Federal Scholarship Tax Credit 2026-20277 | Proposed rule | Oct 2 |
| Federal Scholarship Tax Credit 2026-20264 | Final rule | Oct 2 |
Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in September 2026
Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.