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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

Category: fyiPriority: importantReason: Contains 'proposed regulation' - significant update

Deadline

august

Applies To

1120international

Affected Groups

C-Corp practitioners, International tax practitioners

Related Topics

Original Source

We aggregate public tax updates and provide AI-assisted summaries. Please read the original reporting for full details.

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