Treasury Department Proposed Rule

2026-17764: Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

Comment Period Closed

Public comment closed · opened August 31, 2026.

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Summary

This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations 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 agency’s own summary, as published.

The rule, in full

755 words as published, August 31, 2026. View the original →

Federal Register, Volume 91 Issue 167 (Monday, August 31, 2026) [Federal Register Volume 91, Number 167 (Monday, August 31, 2026)] [Proposed Rules] [Page 55816] From the Federal Register Online via the Government Publishing Office [www.gpo.gov] [FR Doc No: 2026-17764] ======================================================================== Proposed Rules Federal Register ________________________________________________________________________ This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. ======================================================================== Federal Register / Vol. 91, No. 167 / Monday, August 31, 2026 / Proposed Rules [[Page 55816]] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG-115145-25] RIN 1545-BR76 Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

Agency

Internal Revenue Service (IRS), Treasury.

Action

Notice of proposed rulemaking; correction. -----------------------------------------------------------------------

Summary

This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations 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.

Dates

Written or electronic comments and requests for a public hearing must be received by September 17, 2026.

Addresses

Commenters are strongly encouraged to submit public comments electronically via the Federal eRulemaking Portal at https://www.regulations.gov (indicate IRS and REG-115145-25) by following the online instructions for submitting comments. Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The Department of the Treasury (Treasury Department) and the IRS will publish for public availability any comment submitted to the IRS's public docket. Send paper submissions to: CC:PA:01:PR (REG-115145-25), Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.

For Further Information Contact

Concerning the proposed regulations related to section 898(c), Hayley Rassuchine at (202) 317-6936; concerning the proposed regulations related to section 960(d)(4), Le Chen at (202) 317-6936; and concerning submissions of comments and requests for a public hearing, Publications and Regulations at (202) 317-6901 (not toll-free numbers) or by sending an email to [email protected] (preferred).

Supplementary Information

Background The proposed regulations (REG-115145-25) subject to this correction are proposed to be issued under sections 898(c) and 960(d)(4) and certain other provisions of the Internal Revenue Code (Code). Correction of Publication Accordingly, FR Doc. 2026-15614 (REG-115145-25), appearing on page 48794 in the Federal Register on August 3, 2026, is corrected as follows:

1. On page 48799, in the second column, in the first full

paragraph, in the last line of the paragraph, the language ``1.442- 2(b)(1)(i)'' is corrected to read ``1.441-2(b)(1)(i)''.

2. On page 48800, in the second column, in the last paragraph, in

the fourteenth line from the top of the paragraph, the language ``Sec. 1.898(c)-1(c)(4)'' is corrected to read ``Sec. 1.898(c)-1(e)(4)''. Sec. 1.898(c)-1 [Corrected]

3. On page 48801, in the third column, in paragraph (b), the fourth

line from the bottom of the page is corrected to read ``taxpayer described in Sec. 1.901-2(f).''

4. On page 48802, in the third column, in paragraph (e)(2)(i), in

the fourth line from the bottom of the paragraph, the language ``percentage is adjusted'' is corrected to read ``percentage are adjusted''.

5. On page 48803, in the first column, in paragraph (f)(1), in the

second line from the bottom of the paragraph, the language ``before the last day'' is corrected to read ``before the first day''.

6. On page 48805, in the second column, in paragraph (i)(7)(ii)(A),

the eighth line from the bottom of the paragraph is corrected to read ``an income group specific allocation''.

7. On page 48805, in the third column, in paragraph (i)(7)(ii)(B),

the eighth line from the bottom of the paragraph is corrected to read ``an income group specific allocation''.

8. On page 48805, in the third column, in paragraph (i)(8)(ii), in

the first line of the paragraph, the language ``paragraph g'' is corrected to read ``paragraph (d)(4)''. Sec. 1.960-3 [Corrected]

9. On page 48806, in the third column, in paragraph (e)(3)(ii)(B),

in the second line from the bottom of the page, the language ``FC's'' is corrected to read ``FC1's''.

10. On page 48807, in the first column, in paragraph (e)(3)(ii)(B),

in the first line from the top of the page, the language ``FC's'' is corrected to read ``FC1's''. Oluwafunmilayo A. Taylor, Chief, Publications and Regulations Section, Associate Chief Counsel, (Procedure and Administration). [FR Doc. 2026-17764 Filed 8-28-26; 8:45 am] BILLING CODE 4831-GV-P

What this changes

Amends 1 part of the Code of Federal Regulations — the standing rules this notice rewrites.

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