Date: 2026-08-03
Links to Federal Register: HTML, PDF
Document Number: 2026-15614, RIN: 1545-BR76
Action: Notice of proposed rulemaking.
Abstract: 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.
| Notable phrases | Frequency |
|---|---|
| foreign income tax(es) | 157 |
| first required year | 120 |
| succeeding taxable year | 81 |
| specified foreign corporation | 35 |
| relevant succeeding year | 32 |
| specified foreign income taxes | 27 |
| earnings and profits | 23 |
| foreign tax credit | 22 |
| foreign net income tax | 16 |
| income taxes paid | 14 |
| section 901 taxpayer | 14 |
| cfc income group | 13 |
| previously taxed earnings and profits | 11 |
| allocated to the succeeding taxable year | 9 |
| fbcserv income group | 9 |
| foreign income tax assigned | 9 |
| tax assigned to each income group | 7 |
| the section 951a category | 5 |
| ptep account | 5 |
| required to change its taxable year | 4 |
| Reg. Cites | Frequency |
|---|---|
| 1.861-20 | 14 |
| 1.901-2(f)(5) | 10 |
| 1.1502-76(b) | 10 |
| 1.898(c)-1 | 7 |
| 1.898(c)-1(h) | 5 |
| 1.901-2(a) | 4 |
| 1.901-2(f) | 4 |
| 1.960-3(b)(6) | 3 |
| 1.960-3(c)(2) | 3 |
| 1.959-3(b) | 3 |
| 1.964-1(c)(3)(iii) | 3 |
| 1.441-2 | 2 |
| 1.951A-2(c)(7)(viii) | 2 |
| 1.901-1 | 2 |
| 1.987-11 | 2 |
| 1.960-7 | 2 |
| 1.960-3 | 2 |
| 1.951A-2(c)(7) | 2 |
| 1.954-1(d) | 2 |
| 1.951A-2(c)(7)(ii) | 2 |
| Sec. Cites | Frequency |
|---|---|
| 951A | 54 |
| 901 | 22 |
| 960(d)(4) | 22 |
| 3 | 15 |
| 959(a) | 13 |
| 905(c) | 11 |
| 898(c)(2) | 10 |
| 898(c) | 8 |
| 987 | 8 |
| 960(b)(1) | 8 |
| 960(a) | 5 |
| 898(c)(1) | 5 |
| 898 | 5 |
| 706(b) | 4 |
| 898(b) | 4 |
| 960(b) | 4 |
| 960(d)(1) | 4 |
Statistics
Number of pages: 14, words: 15,564, sentences: 530
Average words per sentence: 29