Final rule 2025-22776
Income of Foreign Governments and of International Organizations
This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States.
Source-supplied record
Document details
- Document number
- 2025-22776
- Published
- Dec 15, 2025
- Effective
- Dec 15, 2025
- Comments close
- Not supplied
- Federal Register citation
- 90 FR 57901
Docket identifiers
- TD 10042
CFR references
- Title 26, part 1