# Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss

**Action Urgency Score:** 20/100

| Field | Value |
|---|---|
| Agency | Treasury Department; Internal Revenue Service |
| Type | Proposed rule |
| Action | Notice of proposed rulemaking. |
| Published | 2026-08-26 |
| Comments close | 2026-10-26 |
| Significant | No |
| CFR parts | 26 CFR 1 |
| Summary | 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. |
| Document number | 2026-17365 |

## Why this score


Source: Federal Register API (Office of the Federal Register) (https://www.federalregister.gov/documents/2026/08/26/2026-17365/pro-rata-share-of-subpart-f-income-tested-income-or-tested-loss). Last refreshed: 2026-11-04T21:40:49.974Z.
Data from the Federal Register API; the published Federal Register document is authoritative. Informational only, not legal advice.