INTERNAL REVENUE SERVICE ISSUES PROPOSED RULE: SECTION 898(C) TRANSITION RULE FOR ALLOCATING FOREIGN TAXES AND SECTION 960(D)(4) FOREIGN TAX CREDIT DISALLOWANCE; CORRECTION

WASHINGTON, Aug. 31 -- Internal Revenue Service has issued a proposed rule called: Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction.

The proposed rule was published in the Federal Register on Aug. 31 by Oluwafunmilayo A. Taylor, Chief, Publications and Regulations Section, Associate Chief Counsel, (Procedure and Administration).

Summary: This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Registeron 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 certa...