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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.

Metadata

FieldValue
Federal Register2026-17365
AgenciesInternal Revenue Service, Treasury Department
Publication2026-08-26
Comment closes2026-10-26

Overview

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 shareholde…

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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.

CFA analysis and draft

No draft comment is stored for this docket in the current export.

Technical details
  • report_type: fr-proposed-rules
  • persona: all
  • Source field for draft body: comment_draft_markdown

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