Treasury Sees Midyear Regs on Law’s International-Tax Provisions

The Treasury Department plans to propose a variety of regulations around midyear to implement international provisions of the giant 2025 tax-and-spending law, an official said Thursday.

The proposals include rules on a provision under tax code Section 250 concerning income exclusions under the foreign-derived deduction eligible income regime, or FDDEI, said James Wang, international tax counsel at Treasury, speaking at a Federal Bar Association virtual conference.

Also expected around midyear, Wang said, are regulations under Section 951 concerning how US shareholders calculate their share of a foreign subsidiary’s income under a new method included ...