Data / Federal rules / 2025-22776
Income of Foreign Governments and of International Organizations
The Internal Revenue Service published this final rule in the Federal Register on December 15, 2025. It took effect on December 15, 2025.
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What the agency says
This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States.
Key facts
- Document number
- 2025-22776
- Type
- Final rule
- Action
- Final and temporary regulations
- Agency
- Treasury Department; Internal Revenue Service
- Published
- December 15, 2025
- Takes effect
- December 15, 2025
- Dates
- Effective date: These regulations are effective on December 15, 2025.
- Docket
- TD 10042
- Regulation ID (RIN)
- 1545-BG08
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 20
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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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