dockets: IRS-2026-0859

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id agency_id title docket_type last_modified object_id rin dkabstract category subtype keywords program short_title effective_date organization attrs_raw attr_source
IRS-2026-0859 IRS Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance (REG-115145-25) Rulemaking 2026-09-18T17:10:39Z 0b000064b93e90a0 1545-BR76 Section 70352(c)(1)(C) of the One, Big, Beautiful Bill Act (OBBBA) repealed the one-month deferral election under section 898(c)(2). Foreign corporations with a one-month deferral election in place are required to have a one-month short year in order to transition to the taxable year of their majority U.S. shareholder. These proposed regulations would allocate foreign taxes paid or accrued by a foreign corporation affected by the repeal of the one-month deferral election between its short year and its succeeding taxable year. The proposed regulations would provide the same rules as described in Notice 2025-72 with certain modifications. Section 70312(b) of the OBBBA adds new section 960(d)(4) to the Code. Section 960(d)(4) generally disallows 10 percent of the foreign tax credits otherwise allowable for foreign income taxes (such as withholding taxes) imposed on distributions of previously taxed earnings and profits (PTEP) attributable to inclusions in gross income under section 951A. These proposed regulations would amend the regulations under section 960 to provide guidance on the effective date of section 960(d)(4) and to create new PTEP groups necessary for the implementation of section 960(d)(4). The proposed regulations would provide the same rules as described in Notice 2025-77. REG-115145-25 published August 3, 2026.     ["password"]       CC: ACCI {"displayProperties": [{"name": "organization", "label": "Organization", "tooltip": "Identifies docket's (a regulatory action) orginating agency and/or department, equivalents: Division, Pre-EDOCKET ID."}], "keywords": ["password"], "modifyDate": "2026-09-18T17:10:39Z", "dkAbstract": "Section 70352(c)(1)(C) of the One, Big, Beautiful Bill Act (OBBBA) repealed the one-month deferral election under section 898(c)(2). Foreign corporations with a one-month deferral election in place are required to have a one-month short year in order to transition to the taxable year of their majority U.S. shareholder. These proposed regulations would allocate foreign taxes paid or accrued by a foreign corporation affected by the repeal of the one-month deferral election between its short year and its succeeding taxable year. The proposed regulations would provide the same rules as described in Notice 2025-72 with certain modifications. \nSection 70312(b) of the OBBBA adds new section 960(d)(4) to the Code. Section 960(d)(4) generally disallows 10 percent of the foreign tax credits otherwise allowable for foreign income taxes (such as withholding taxes) imposed on distributions of previously taxed earnings and profits (PTEP) attributable to inclusions in gross income under section 951A. These proposed regulations would amend the regulations under section 960 to provide guidance on the effective date of section 960(d)(4) and to create new PTEP groups necessary for the implementation of section 960(d)(4). The proposed regulations would provide the same rules as described in Notice 2025-77.\nREG-115145-25 published August 3, 2026.\n", "agencyId": "IRS", "program": null, "shortTitle": null, "subType2": null, "title": "Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance (REG-115145-25)", "generic": null, "field1": null, "docketType": "Rulemaking", "petitionNbr": null, "rin": "1545-BR76", "organization": "CC: ACCI", "legacyId": null, "subType": null, "category": null, "field2": null, "effectiveDate": null, "objectId": "0b000064b93e90a0"} single_get

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