Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

Issuing agencies

Abstract

This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on 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 certain distributions of previously taxed earnings and profits.

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<title>Federal Register, Volume 91 Issue 167 (Monday, August 31, 2026)</title>
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[Federal Register Volume 91, Number 167 (Monday, August 31, 2026)]
[Proposed Rules]
[Page 55816]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-17764]


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Proposed Rules
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains notices to the public of 
the proposed issuance of rules and regulations. The purpose of these 
notices is to give interested persons an opportunity to participate in 
the rule making prior to the adoption of the final rules.

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Federal Register / Vol. 91, No. 167 / Monday, August 31, 2026 / 
Proposed Rules

[[Page 55816]]



DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-115145-25]
RIN 1545-BR76


Section 898(c) Transition Rule for Allocating Foreign Taxes and 
Section 960(d)(4) Foreign Tax Credit Disallowance; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; correction.

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SUMMARY: This document contains corrections to the proposed regulations 
(REG-115145-25), published in the Federal Register on 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 certain 
distributions of previously taxed earnings and profits.

DATES: Written or electronic comments and requests for a public hearing 
must be received by September 17, 2026.

ADDRESSES: Commenters are strongly encouraged to submit public comments 
electronically via the Federal eRulemaking Portal at <a href="https://www.regulations.gov">https://www.regulations.gov</a> (indicate IRS and REG-115145-25) by following the 
online instructions for submitting comments. Once submitted to the 
Federal eRulemaking Portal, comments cannot be edited or withdrawn. The 
Department of the Treasury (Treasury Department) and the IRS will 
publish for public availability any comment submitted to the IRS's 
public docket. Send paper submissions to: CC:PA:01:PR (REG-115145-25), 
Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin 
Station, Washington, DC 20044.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations 
related to section 898(c), Hayley Rassuchine at (202) 317-6936; 
concerning the proposed regulations related to section 960(d)(4), Le 
Chen at (202) 317-6936; and concerning submissions of comments and 
requests for a public hearing, Publications and Regulations at (202) 
317-6901 (not toll-free numbers) or by sending an email to 
<a href="/cdn-cgi/l/email-protection#a7d7d2c5cbcec4cfc2c6d5cec9c0d4e7ced5d489c0c8d1"><span class="__cf_email__" data-cfemail="d3a3a6b1bfbab0bbb6b2a1babdb4a093baa1a0fdb4bca5">[email&#160;protected]</span></a> (preferred).

SUPPLEMENTARY INFORMATION:

Background

    The proposed regulations (REG-115145-25) subject to this correction 
are proposed to be issued under sections 898(c) and 960(d)(4) and 
certain other provisions of the Internal Revenue Code (Code).

Correction of Publication

    Accordingly, FR Doc. 2026-15614 (REG-115145-25), appearing on page 
48794 in the Federal Register on August 3, 2026, is corrected as 
follows:
    1. On page 48799, in the second column, in the first full 
paragraph, in the last line of the paragraph, the language ``1.442-
2(b)(1)(i)'' is corrected to read ``1.441-2(b)(1)(i)''.
    2. On page 48800, in the second column, in the last paragraph, in 
the fourteenth line from the top of the paragraph, the language ``Sec.  
1.898(c)-1(c)(4)'' is corrected to read ``Sec.  1.898(c)-1(e)(4)''.


Sec.  1.898(c)-1  [Corrected]

    3. On page 48801, in the third column, in paragraph (b), the fourth 
line from the bottom of the page is corrected to read ``taxpayer 
described in Sec.  1.901-2(f).''
    4. On page 48802, in the third column, in paragraph (e)(2)(i), in 
the fourth line from the bottom of the paragraph, the language 
``percentage is adjusted'' is corrected to read ``percentage are 
adjusted''.
    5. On page 48803, in the first column, in paragraph (f)(1), in the 
second line from the bottom of the paragraph, the language ``before the 
last day'' is corrected to read ``before the first day''.
    6. On page 48805, in the second column, in paragraph (i)(7)(ii)(A), 
the eighth line from the bottom of the paragraph is corrected to read 
``an income group specific allocation''.
    7. On page 48805, in the third column, in paragraph (i)(7)(ii)(B), 
the eighth line from the bottom of the paragraph is corrected to read 
``an income group specific allocation''.
    8. On page 48805, in the third column, in paragraph (i)(8)(ii), in 
the first line of the paragraph, the language ``paragraph g'' is 
corrected to read ``paragraph (d)(4)''.

Sec.  1.960-3 [Corrected]

    9. On page 48806, in the third column, in paragraph (e)(3)(ii)(B), 
in the second line from the bottom of the page, the language ``FC's'' 
is corrected to read ``FC1's''.
    10. On page 48807, in the first column, in paragraph (e)(3)(ii)(B), 
in the first line from the top of the page, the language ``FC's'' is 
corrected to read ``FC1's''.

Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Section, Associate Chief Counsel, 
(Procedure and Administration).
[FR Doc. 2026-17764 Filed 8-28-26; 8:45 am]
BILLING CODE 4831-GV-P


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