Data / Federal rules / 2026-17764
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction
The Internal Revenue Service published this proposed rule in the Federal Register on August 31, 2026. Comments closed on September 17, 2026.
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What the agency says
This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations 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.
Key facts
- Document number
- 2026-17764
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking; correction
- Agency
- Treasury Department; Internal Revenue Service
- Published
- August 31, 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
- Pages
- 1
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Everything from the Internal Revenue Service · 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.