Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance
Treasury Department; Internal Revenue Service: proposed rule. Dated 94 days ago, it serves as a historical benchmark. Score 20/100. As of 2026-11-04, from Federal Register API (Office of the Federal Register).
Data as of · Compiled by Zalwin from Federal Register API (Office of the Federal Register)
Free preview: all 9 published fields of this record are shown below. Locked: 38 related FederalRegisterCompliancePulse records and the 5-column CSV export.
| Field | Value |
|---|---|
| Agency | Treasury Department; Internal Revenue Service |
| Type | Proposed rule |
| Action | Notice of proposed rulemaking. |
| Published | 2026-08-03 |
| Comments close | 2026-09-17 |
| Significant | No |
| CFR parts | 26 CFR 1 |
| Summary | This document contains proposed regulations that relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election and to the disallowance of foreign tax credits on certain distributions of previously taxed earnings and profits. The proposed regulations would affect taxpayers that operate in foreign countries through certain foreign corporations and taxpayers that claim the foreign tax credit. |
| Document number | 2026-15614 |
| Peer records CSV (39 records) | 🔒 Click to unlock → |
| CRM-ready export with official source URLs | 🔒 Click to unlock → |
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- Source agency: Federal Register API (Office of the Federal Register)
- Record date: 2026-08-03
- Data refreshed: 2026-11-04
- Refunds on request within 14 days
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LIVE PUBLIC DATA Source: Federal Register API (Office of the Federal Register) · Last refreshed: Wed, 04 Nov 2026 09:17:43 GMT
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Peer benchmark and outreach value: Treasury Department; Internal Revenue Service and 39 internal-revenue-service peers
- internal-revenue-service FederalRegisterCompliancePulse records like this one: 39
- Timing: Low: older than 30 days
- Estimated pipeline if you contact every internal-revenue-service peer: $7,800 (peers × rate × deal size; an estimate from your assumptions, not a forecast)
20 / 100 Action Urgency Score
What is the FederalRegisterCompliancePulse record for Treasury Department; Internal Revenue Service?
Treasury Department; Internal Revenue Service published a proposed rule on 2026-08-03, comments due 2026-09-17: Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance.
How does Treasury Department; Internal Revenue Service compare to other FederalRegisterCompliancePulse records?
It is 94 days old; check the official source for later updates before acting. Its Action Urgency Score of 20/100 is modest; treat it as background rather than a priority.
Treasury Department; Internal Revenue Service vs. top 2 peers
| Organization | Location | Record date |
|---|---|---|
| Treasury Department; Internal Revenue Service | internal-revenue-service | 2026-08-03 |
| Treasury Department; Internal Revenue Service; Labor Department; Employee Benefits Security Administration; Health and Human Services Department | internal-revenue-service | 2026-10-06 |
| Treasury Department; Internal Revenue Service; Labor Department; Employee Benefits Security Administration; Health and Human Services Department | internal-revenue-service | 2026-08-28 |
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Data from the Federal Register API; the published Federal Register document is authoritative. Informational only, not legal advice.