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

What it does

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 Internal Revenue Service's summary, as published in the Federal Register.

What it would change

1 part of Title 26 of the Code of Federal Regulations:

26 CFR 1

Before this

No earlier Federal Register document under regulation identifier 1545-BR76 since Jan. 1, 2025.

Since then:

• Aug. 31, 2026 Notice of proposed rulemaking; correction. Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

What happens next and when

Written or electronic comments and requests for a public hearing must be received by September 17, 2026.

The agency's dates, word for word.

Check it yourself

• The document in the Federal Register
• Docket IRS-2026-0859 on Regulations.gov
• Title 26 on eCFR

The record as published

Source: the Federal Register (public domain). The document in the Federal Register