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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

The document on federalregister.gov PDF

Other documents from the Internal Revenue Service

Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · 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.