INCOME TAX

REG-115646-25, page 414. These proposed regulations would provide rules for determining a United States shareholder’s pro rata share of subpart F income, tested income, or tested loss of a controlled foreign corporation that reflect amendments made by Public Law 11921, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). The proposed regulations would also modify certain information reporting requirements and the applicability dates of certain related rules. Additionally, the proposed regulations include the rules described in Notice 202575 regarding the transition rule contained in section 70354(c) (2) of the OBBBA.