Proposed rule · 2026-17019

Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property

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.