Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
The comment period closed Oct 26, 2026.
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.
Summary from the Federal Register.
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Full history
- Aug 26, 2026
Rule published
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
Treasury Department
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From the Federal Register. This record was last updated Oct 26, 2026. About our data
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