Treasury Plans Clarification of Foreign-Government Income Regs

The Treasury Department is planning guidance “in the very near future” to address an issue with the application of regulations on foreign governments’ income from US investments, a Treasury official said Friday.

The guidance will clarify applicability dates of proposed rules issued in December under Section 892, said Teisha Ruggiero, an attorney-adviser in Treasury’s Office of the International Tax Counsel, speaking at the American Bar Association Tax Section’s May meeting in Washington. That will ensure that existing investments and investment structures won’t be subject to those rules, she said.

Certain foreign-government income is generally exempt from US ...