Data / Federal rules / 2026-17365
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
The Internal Revenue Service published this proposed rule in the Federal Register on August 26, 2026. Comments are due by October 26, 2026.
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What the agency says
This document contains proposed regulations relating to the determination of a United States shareholder's pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation. The proposed regulations would affect shareholders of foreign corporations, including United States shareholders of controlled foreign corporations.
Key facts
- Document number
- 2026-17365
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- August 26, 2026
- Comments due
- October 26, 2026
- Dates
- Written or electronic comments and requests for a public hearing must be received by October 26, 2026.
- Docket
- REG-115646-25
- Regulation ID (RIN)
- 1545-BR77
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 26
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Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in August 2026
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.