Tax Coda

Tax Coda

IRS finalizes §892 rules on foreign government investment income

26 CFR Part 1. TD 10042. RIN 1545-BG08

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Tax Coda
Dec 15, 2025
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Foreign governments get more explicit rules on when U.S. investment income stays tax-exempt and when it does not. The IRS tightened definitions, expanded safe harbors, and finally cleaned up decades of temporary regulations.

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Treasury and the IRS issued final regulations under §892 governing when income earned by foreign governments from U.S. …

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