Federal Register: proposed rule

Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

Federal Register published "Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income" on 2026-09-11. First seen on Kresmion 2026-10-26 18:24 UTC.

As of 2026-09-11. 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): 2026-09-11 (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 proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.

The publisher's words, as published.

Federal Register document

Document number: 2026-18645
Document type: Proposed Rule
Status: Published

Cite this data

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Upstream: Federal Register

Kresmion, "Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income", data as of 2026-09-11, https://kresmion.com/record/4984. Upstream data: Federal Register.

Link to this data (HTML):

<a href="https://kresmion.com/record/4984">Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income (Kresmion)</a>