Income of Foreign Governments and of International Organizations

Document 2025-22776 is a Final Rule published by the Department of the Treasury in the Federal Register on December 15, 2025, with an effective date of December 15, 2025. This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States. View the original at https://www.federalregister.gov/documents/2025/12/15/2025-22776/income-of-foreign-governments-and-of-international-organizations.

No. Document 2025-22776 is not classified as economically significant under Executive Order 12866. Economically significant rules require OIRA review and are estimated to have impacts of $100 million or more per year.