Federal Register (IRS) · Aug 31, 2026
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction
Tax Brief summary and classification of the original reporting.
Bottom Line
💡 Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d.... Worth reviewing for potential client impact.
Summary
[Proposed Rule] 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.
Classification
Deadline
august
Applies To
Affected Groups
C-Corp practitioners, International tax practitioners
Related Topics
Original Source
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