Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance

Document 2026-15614 is a Proposed Rule published by the Department of the Treasury in the Federal Register on August 3, 2026. This document contains proposed regulations that relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election and to the disallowance of foreign tax credits on certain distributions of previously taxed earnings and profits. The proposed regulations would affect taxpayers that operate in foreign countries through certain foreign corporations and taxpayers that claim the foreign tax credit. View the original at https://www.federalregister.gov/documents/2026/08/03/2026-15614/section-898c-transition-rule-for-allocating-foreign-taxes-and-section-960d4-foreign-tax-credit.

No. Document 2026-15614 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.