Income of Foreign Governments and of International Organizations (CC-00349656-26)

These proposed regulations would withdraw applicability dates and propose new applicability dates relating to proposed regulations under section 892 of the Internal Revenue Code for determining whether an acquisition of debt by a foreign government is commercial activity and whether a foreign government has effective control of an entity. These proposed regulations would provide transitional relief to existing holdings of foreign governments when finalized. CC-00349656-26. Published June 1, 2026.