31 July 2026 BREAKING TAX NEWS | IRS proposes regulations on OBBBA repeal of 'one-month deferral election' Today, the IRS proposed regulations (REG-115145-25) on the repeal of the "one-month deferral election" in IRC Section 898(c)(2) by the "One Big Beautiful Bill" Act (OBBBA). The proposed regulations would allocate certain foreign income taxes that accrue during the mandatory, one-month "short year" caused by the election's repeal, as outlined in Notice 2025-72, with some modifications (see Tax Alert 2025-2608). The proposed regulations also provide effective date guidance on the disallowance under IRC Section 960(d)(4) of foreign tax credits claimed on certain previously taxed earnings and profits, as described in Notice 2025-77. A Tax Alert is forthcoming.
Document ID: 2026-1661 | ||
