Income of Foreign Governments and of International Organizations
other · IRS · Rule · Published 2025-12-15 · Effective 2025-12-15 · 90 FR 57901
Document
Document number
2025-22776
Federal Register citation
90 FR 57901
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2025-12-15
Effective date
2025-12-15
Treasury docket
TD 10042
Abstract
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.