Federal Register: proposed rule

Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

Federal Register published "Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction" on 2026-08-31. First seen on Kresmion 2026-10-26 18:24 UTC.

As of 2026-08-31. Source: www.federalregister.gov. Method and limitations.

The record

Publisher: Federal Register
Agency: Treasury Department; Internal Revenue Service
Source: Federal Register
Kind: Federal Register: proposed rule
Jurisdiction: United States
Topics: Other
Importance: Notable, the middle of three tiers Kresmion sets by fixed rules from the source's own fields
Published (source time): 2026-08-31 (the source gives a date only)
First seen on Kresmion: 2026-10-26 18:24 UTC

The original

Open the original on www.federalregister.gov

PDF (Federal Register)

Link not checked yet: one check due 2026-11-25 (the source published this record more than 7 days before Kresmion first saw it).

Source: Federal Register (federalregister.gov). U.S. government work, public domain.

The publisher's summary

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.

The publisher's words, as published.

Federal Register document

Document number: 2026-17764
Document type: Proposed Rule
Status: Published

Cite this data

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Upstream: Federal Register

Kresmion, "Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction", data as of 2026-08-31, https://kresmion.com/record/2610. Upstream data: Federal Register.

Link to this data (HTML):

<a href="https://kresmion.com/record/2610">Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction (Kresmion)</a>