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

**Action Urgency Score:** 20/100

| Field | Value |
|---|---|
| Agency | Treasury Department; Internal Revenue Service |
| Type | Proposed rule |
| Action | Notice of proposed rulemaking. |
| Published | 2026-09-11 |
| Significant | No |
| CFR parts | 26 CFR 1 |
| Summary | 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. |
| Document number | 2026-18645 |

## Why this score


Source: Federal Register API (Office of the Federal Register) (https://www.federalregister.gov/documents/2026/09/11/2026-18645/allocation-and-apportionment-of-deductions-to-foreign-source-section-951a-category-income-and). 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.