Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income
This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.
What this item does
The short version, using the agency's own summary text.
This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.
Notice of proposed rulemaking.
Important dates
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Published
September 11, 2026
Who published it
The agencies listed in the official filing.
Federal rulebook sections mentioned
These are the parts of the Code of Federal Regulations cited in the filing.