29 May 2026 Treasury and IRS issue proposed regulations under IRC Section 892 to provide transition rules and grandfather protection to sovereign foreign investors The Treasury Department and the IRS on May 29, 2026, issued additional proposed regulations (CC-00349656-26) to address the applicability dates of previously proposed regulations under IRC Section 892 (see Tax Alert 2025-2594), which exempts from tax certain income of foreign government and sovereign wealth funds derived from passive US investments. The proposed regulations would provide grandfathering protections and transition relief to foreign governments with investments in the United State. A Tax Alert is forthcoming.
Document ID: 2026-1159 | ||
