These proposed regulations primarily implement the statutory mandates enacted under Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA).
These proposed regulations primarily implement the statutory mandates enacted under Public Law 119-21, 139 Stat.
72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA).
Specifically, the rulemaking updates existing regulations under Treasury Regulation § 1.250(b)-1, amends Treasury Regulation § 1.861-8 and § 1.904(b)-3, and introduces new Proposed Treasury Regulation §...
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These proposed regulations primarily implement the statutory mandates enacted under Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). Specifically, the rulemaking updates existing regulations under Treasury Regulation § 1.250(b)-1, amends Treasury Regulation § 1.861-8 and § 1.904(b)-3, and introduces new Proposed Treasury Regulation § 1.904(b)-4.
Department of the Treasury, Internal Revenue Service, Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, Notice of Proposed Rulemaking, REG-117273-25, RIN 1545-BR90, 26 C.F.R. This article provides tax practitioners, CPAs, and Enrolled Agents (EAs) with a rigorous technical examination of the background, statutory revisions, administrative rationale, effective dates, and taxpayer reliance rules established by Treasury in these proposed regulations.
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