Treasury Department, Internal Revenue Service
This document contains proposed regulations under section 250 of the Internal Revenue Code (Code) that provide guidance on certain income of a domestic corporation that is excluded in the determination of deduction eligible income. This category of income consists of income and gain from the sale or other disposition of intangible property and any other property of a type that is subject to depreciation, amortization, or depletion. The proposed regulations would affect domestic corporations with foreign-derived deduction eligible income.
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 [REG-117130-25] RIN 1545-BR85 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. ( printed page 53793) SUMMARY: This document contains proposed regulations under section 250 of the Internal Revenue Code (Code) that provide guidance on certain income of a domestic corporation that is excluded in the determination of deduction eligible income. This category of income consists of income and gain from the sale or other disposition of intangible property and any other property of a type that is subject to depreciation, amortization, or depletion. The proposed regulations would affect domestic corporations with foreign-derived deduction eligible income. DATES: Written or electronic comments must be received by October 5, 2026. ADDRESSES: Commenters are strongly encouraged to submit comments electronically via the Federal eRulemaking Portal at https://www.regulations.gov (indicate IRS and REG-117130-25) 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 Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn.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 electronically or on paper to its public docket. Send paper submissions to CC:PA:01:PR (REG-117130-25), Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. FOR FURTHE…
Citation: 91 FR 53792
