IRS Internal Revenue Bulletin: I.R.B. 2026-3 Released

The IRS has published its Internal Revenue Bulletin. The bulletin includes proposed regulations on taxation of foreign governments’ income from investments in the United States. The proposed regulations provide guidance for determining when an acquisition of debt by a foreign government is a commercial activity and when a foreign government has effective control of an entity engaged in commercial activity. These proposed regulations will affect foreign governments that derive income from sources within the United States. [Internal Revenue Bulletin 2026-3 (Jan. 09, 2026)]

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