Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

What it does

This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.

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-BR90 since Jan. 1, 2025.

What happens next and when

Written or electronic comments and requests for a public hearing must be received by November 10, 2026.

The agency's dates, word for word.

Check it yourself

• The document in the Federal Register
• Docket IRS-2026-1222 on Regulations.gov
• Title 26 on eCFR

The record as published

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