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Proposed RuleOpen for Comment2026-108412026-06-01

Income of Foreign Governments and of International Organizations

Treasury Department, Internal Revenue Service

Abstract

This document contains proposed regulations regarding the applicability dates of proposed rules relating to the taxation of the income of foreign governments from investment in the United States. This document also withdraws a portion of the proposed regulations published on December 15, 2025, relating to applicability dates.

Action & Dates

Action
Notice of proposed rulemaking; partial withdrawal of proposed rulemaking.
Dates
Written or electronic comments and requests for a public hearing must be received by July 31, 2026. As of June 1, 2026, proposed Sec. Sec. 1.892-4(d) and 1.892-5(e), contained in the notice of proposed rulemaking published in the Federal Register on December 15, 2025 (90 FR 57928), are withdrawn.

CFR References

Topics

Income taxesReporting and recordkeeping requirements

Public Comment

Comments Close
2026-07-31 — Open for comment

Document Excerpt

Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [CC-00349656-26] RIN 1545-BR10 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking; partial withdrawal of proposed rulemaking. SUMMARY: This document contains proposed regulations regarding the applicability dates of proposed rules relating to the taxation of the income of foreign governments from investment in the United States. This document also withdraws a portion of the proposed regulations published on December 15, 2025, relating to applicability dates. DATES: Written or electronic comments and requests for a public hearing must be received by July 31, 2026. As of June 1, 2026, proposed §§  1.892-4(d) and 1.892-5(e), contained in the notice of proposed rulemaking published in the Federal Register on December 15, 2025 ( 90 FR 57928 ), are withdrawn. ADDRESSES: Commenters are strongly encouraged to submit public comments electronically via the Federal eRulemaking Portal at https://www.regulations.gov (indicate IRS and CC-00349656-26) by following the online instructions for submitting comments. Requests for a public hearing must be submitted as prescribed in the “Comments and Requests for a Public Hearing” section. 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 comments submitted to the IRS

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Full Document

Citation: 91 FR 32366