Every article on this site is written by AI from official sources and checked by a second AI. How it works
Proposed rule

Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss

Built by the Tribune's code from the Federal Register. No AI wrote this page. Published in the Federal Register Aug. 26, 2026. Document 2026-17365. Updated Nov. 6, 2026.

What it does

This document contains proposed regulations relating to the determination of a United States shareholder's pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation. The proposed regulations would affect shareholders of foreign corporations, including United States shareholders of controlled foreign corporations.

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-BR77 since Jan. 1, 2025.

What happens next and when

Written or electronic comments and requests for a public hearing must be received by October 26, 2026.

The agency's dates, word for word.

Document number2026-17365
ActionNotice of proposed rulemaking.
AgenciesTreasury Department; Internal Revenue Service
PublishedAug. 26, 2026
Comments closeOct. 26, 2026
Regulation identifier (RIN)1545-BR77
DocketIRS-2026-1123

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