Data / Federal rules / 2025-08743
Previously Taxed Earnings and Profits and Related Basis Adjustments
The Internal Revenue Service published this proposed rule in the Federal Register on May 16, 2025. Comments closed on July 14, 2025.
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What the agency says
This document reopens the period to submit comments for a notice of proposed rulemaking (REG-105479-18), which was published in the Federal Register on Monday, December 2, 2024. The proposed regulations address previously taxed earnings and profits of foreign corporations and related basis adjustments. The proposed regulations affect foreign corporations with previously taxed earnings and profits and their shareholders.
Key facts
- Document number
- 2025-08743
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking; reopening of comment period
- Agency
- Treasury Department; Internal Revenue Service
- Published
- May 16, 2025
- Comments due
- July 14, 2025
- Dates
- The comment period to submit written or electronic comments for the notice of proposed rulemaking, REG-105479-18, 89 FR 95362 (December 2, 2024) is reopened until July 14, 2025.
- Docket
- REG-105479-18
- Regulation ID (RIN)
- 1545-BO61
- Code of Federal Regulations
- 26 CFR 1
- Significant
- Yes, under Executive Order 12866
- Pages
- 1
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Everything from the Internal Revenue Service · Published in May 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.