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This document contains final regulations relating to the taxation of the income of foreign governments from investments in the United States. In particular, these final regulations provide guidance for determining when a foreign government is engaged in commercial activity and when an entity is a controlled commercial entity. The final regulations will affect foreign governments that derive income from sources within the United States.
Published
Dec 15, 2025
Effective
Dec 15, 2025
Citation
90 FR 57901
Agencies
2
Full text not available in our database.
View on Federal Register →Get a plain-English explanation of what this regulation does, which agencies are responsible, and how it affects existing rules.
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TD 10042
1545-BG08
26 CFR 1