2025-22775Proposed Rule

IRS Decides When Foreign Governments Get Tax Bills

Published Date: 12/15/2025

Proposed Rule

Summary

The IRS is proposing new rules to clarify when foreign governments’ earnings from U.S. investments count as business income and when they control companies doing business here. These changes mainly affect foreign governments earning money in the U.S. and could impact how their income is taxed. Comments on the proposal are open until February 13, 2026, so interested parties should speak up soon!

No Economic Impacts Identified for this Document

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Key Dates

Published Date
Comments Due
12/15/2025
2/13/2026

Department and Agencies

Department
Independent Agency
Agency
Treasury Department
Internal Revenue Service
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