U.S. Proposed Regulations on Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

The U.S. IRS and Treasury have issued a notice of proposed rulemaking, Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, which was published in the Federal Register on 11 September 2026. The document contains proposed tax regulations to update how deductions are allocated to foreign source Section 951A category income for foreign tax credit limitation purposes and for calculating deduction eligible income. These updates a…