Proposed rule · 2026-18645

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

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.