Data / Federal rules / 2025-22874
Entities Wholly Owned by Indian Tribal Governments
The Internal Revenue Service published this final rule in the Federal Register on December 16, 2025. It took effect on January 15, 2026.
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What the agency says
This document contains final regulations regarding the Federal tax classification of entities wholly owned by Indian Tribal governments (Tribes). The final regulations provide that entities that are wholly owned by Tribes and organized or incorporated under the laws of one or more of the Tribes that own them generally are not recognized as separate entities for Federal tax purposes. The final regulations also provide that such entities, as well as certain Tribal corporations chartered by the Department of the Interior (DOI), are recognized as separate entities for Federal employment and certain Federal excise tax purposes. In addition, the final regulations provide that, for purposes of making elective payment elections (including determining eligibility for and the consequences of such elections) for energy credits under the Inflation Reduction Act of 2022, each of these types of Tribal entities is treated as an instrumentality of one or more Indian Tribal governments.
Key facts
- Document number
- 2025-22874
- Type
- Final rule
- Action
- Final rule
- Agency
- Treasury Department; Internal Revenue Service
- Published
- December 16, 2025
- Takes effect
- January 15, 2026
- Dates
- Effective date: These regulations are effective on January 15, 2026.
- Docket
- TD 10039
- Regulation ID (RIN)
- 1545-BQ13
- Code of Federal Regulations
- 26 CFR 1; 26 CFR 301
- Topics
- Employment taxes; Estate taxes; Excise taxes; Gift taxes; Income taxes; Penalties; Reporting and recordkeeping requirements
- Pages
- 13
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Everything from the Internal Revenue Service · Rules on employment taxes · Rules on estate taxes · Rules on excise taxes · Published in December 2025
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.