Entities Wholly Owned by Indian Tribal Governments

Document 2025-22874 is a Final Rule published by the Department of the Treasury in the Federal Register on December 16, 2025, with an effective date of January 15, 2026. This document contains final regulations regarding the Federal tax classification of entities wholly owned by Indian Tribal governments (Tribes). The final regulations provide that entities that are wholly owned by Tribes and organized or incorporated under the laws of one or more of the Tribes that own them generally are not recognized as separate entities for Federal tax purposes. The final regulations also provide that such entities, as well as certain Tribal corporations chartered by the Department of the Interior (DOI), are recognized as separate entities for Federal employment and certain Federal excise tax purposes. In addition, the final regulations provide that, for purposes of making elective payment elections (including determining eligibility for and the consequences of such elections) for energy credits under the Inflation Reduction Act of 2022, each of these types of Tribal entities is treated as an instrumentality of one or more Indian Tribal governments. View the original at https://www.federalregister.gov/documents/2025/12/16/2025-22874/entities-wholly-owned-by-indian-tribal-governments.

No. Document 2025-22874 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.