Data / Federal rules / 2025-22775
Income of Foreign Governments and of International Organizations
The Internal Revenue Service published this proposed rule in the Federal Register on December 15, 2025. Comments closed on February 13, 2026.
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What the agency says
This document contains proposed regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these proposed regulations provide guidance for determining when an acquisition of debt by a foreign government is considered to be commercial activity, and when a foreign government has effective control of an entity engaged in commercial activities. These proposed regulations will affect foreign governments that derive income from sources within the United States.
Key facts
- Document number
- 2025-22775
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- December 15, 2025
- Comments due
- February 13, 2026
- Dates
- Written or electronic comments and requests for a public hearing must be received by February 13, 2026.
- Docket
- REG-101952-24
- Regulation ID (RIN)
- 1545-BR10
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 10
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Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in December 2025
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