# Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance

**Action Urgency Score:** 20/100

| 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 |

## Why this score


Source: Federal Register API (Office of the Federal Register) (https://www.federalregister.gov/documents/2026/08/03/2026-15614/section-898c-transition-rule-for-allocating-foreign-taxes-and-section-960d4-foreign-tax-credit). Last refreshed: 2026-11-04T09:17:43.641Z.
Data from the Federal Register API; the published Federal Register document is authoritative. Informational only, not legal advice.