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Proposed Rule2026-17365

Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
August 26, 2026

Issuing agencies

Treasury DepartmentInternal Revenue Service

Abstract

This document contains proposed regulations relating to the determination of a United States shareholder's pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation. The proposed regulations would affect shareholders of foreign corporations, including United States shareholders of controlled foreign corporations.

Indexed from Federal Register on August 26, 2026.

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.