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

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)

2026-08-03 (the source gives a date only)

First seen on Kresmion

2026-10-26 18:24 UTC

The original

• PDF (Federal Register)

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

The publisher's summary

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.

The publisher's words, as published.

Federal Register document

Document number

2026-15614

Document type

Proposed Rule

Status

Published