dockets: IRS-2026-1123

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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-2026-1123 IRS Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss (REG-115646-25) Rulemaking 2026-09-11T11:55:51Z 0b000064b949ad1e 1545-BR77 These proposed regulations would provide rules for determining a United States shareholder’s pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation that reflect amendments made by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). The proposed regulations would also modify certain information reporting requirements and the applicability dates of certain related rules. Additionally, the proposed regulations include the rules described in Notice 2025-75 regarding the transition rule contained in section 70354(c)(2) of the OBBBA. REG-115646-25. Published August 26, 2026.     ["password"]       CC: INTL {"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": "2026-09-11T11:55:51Z", "dkAbstract": "These proposed regulations would provide rules for determining a United States shareholder\u2019s pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation that reflect amendments made by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). The proposed regulations would also modify certain information reporting requirements and the applicability dates of certain related rules. Additionally, the proposed regulations include the rules described in Notice 2025-75 regarding the transition rule contained in section 70354(c)(2) of the OBBBA. REG-115646-25. Published August 26, 2026.", "agencyId": "IRS", "program": null, "shortTitle": null, "subType2": null, "title": "Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss (REG-115646-25)", "generic": null, "field1": null, "docketType": "Rulemaking", "petitionNbr": null, "rin": "1545-BR77", "organization": "CC: INTL", "legacyId": null, "subType": null, "category": null, "field2": null, "effectiveDate": null, "objectId": "0b000064b949ad1e"} single_get

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