Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
Treasury Department / Internal Revenue Service
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.
The comment period closed on October 26, 2026. The agency now reviews the comments. If it goes ahead, it publishes a final rule in the Federal Register that responds to significant comments. We link it here when it appears. See what is open for comment now.
From the Federal Register as of November 3, 2026. Deadlines can change; the official document governs. Not legal advice.
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