HIGHLIGHTS Bulletin No. 2026–3 OF THIS ISSUE January 12, 2026
INCOME TAX
Internal Revenue Bulletin 2026-3 · 2026-10-03 edition · updated 2026-10-04 · United States
REG-101952-24, page 349. These proposed regulations relate to the taxation of the income of foreign governments from investments in
Finding Lists begin on page ii.
the United States. In particular, these proposed regula tions provide guidance for determining when an acqui sition of debt by a foreign government is considered to be 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.
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