Data / Federal rules / 2026-15614
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance
The Internal Revenue Service published this proposed rule in the Federal Register on August 3, 2026. Comments closed on September 17, 2026.
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What the agency says
This document contains proposed regulations that relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election and to the disallowance of foreign tax credits on certain distributions of previously taxed earnings and profits. The proposed regulations would affect taxpayers that operate in foreign countries through certain foreign corporations and taxpayers that claim the foreign tax credit.
Key facts
- Document number
- 2026-15614
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- August 3, 2026
- Comments due
- September 17, 2026
- Dates
- Written or electronic comments and requests for a public hearing must be received by September 17, 2026.
- Docket
- REG-115145-25
- Regulation ID (RIN)
- 1545-BR76
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 14
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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.