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Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

Proposed Rule
Treasury Department, Internal Revenue Service
Proposed Rule
September 11, 2026
2026-18645
26 CFR 1

πŸ“„ Summary

This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations would affect taxpayers that operate in foreign countries through foreign corporations and domestic corporations that claim the deduction for foreign-derived deduction eligible income.
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