1545-BR88 202510 The Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions 1545 Internal Revenue Service IRS 1500 Department of the Treasury TREAS Guidance Related to Sourcing Certain Foreign Branch Sales Income of Inventory Produced in the United States for Purposes of the Foreign Tax Credit

Regulations under section 904 to implement the addition of section 904(b)(6) by section 70313 of the One, Big, Beautiful, Bill Act regarding sourcing certain foreign branch sales income related to inventory produced in the United States for purposes of the foreign tax credit.

]]> Other Significant First Time Published in The Unified Agenda Proposed Rule Stage No No Regulatory Not Yet Determined Pub. L. 119-21 26 U.S.C. 904(d)(7) and 7805(a) No NPRM 08/00/2026 REG-117156-25 (NPRM) Drafter attorney: Jacob Nava (202) 317-4432 Reviewer attorney: Tracy Villecco (202) 317-4965 Treasury attorney: Jonathan Galin (202) 622-4729 INTL No None No No No No Jacob Nava Attorney 1500 Department of the Treasury TREAS 202 317-4432 jacob.l.nava@irscounsel.treas.gov 1111 Constitution Avenue NW, Room 5550, Washington DC 20224