Income of Foreign Governments and of International Organizations

Bottom Line

💡 Income of Foreign Governments and of International Organizations. Worth reviewing for potential client impact.

Summary

[Proposed Rule] This document contains proposed regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these proposed regulations provide guidance for determining when an acquisition of debt by a foreign government is considered to be commercial activity, and when a foreign government has effective control of an entity engaged in commercial activities. These proposed regulations will affect foreign governments that derive income from sources within the United States.

Classification

Applies To

Affected Groups

International tax practitioners

Related Topics