Proposed rule 2026-17365
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
This document contains proposed regulations relating to the determination of a United States shareholder's pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation. The proposed regulations would affect shareholders of foreign corporations, including United States shareholders of controlled foreign corporations.
Source-supplied record
Document details
- Document number
- 2026-17365
- Published
- Aug 26, 2026
- Effective
- Not supplied
- Comments close
- Not supplied
- Federal Register citation
- 91 FR 55037
Docket identifiers
- REG-115646-25
CFR references
- Title 26, part 1