Treasury Previews International Regulations Under GOP Tax Law (1)

Corporate taxpayers can expect four notices of proposed rulemaking and final regulations on international provisions from Republicans’ 2025 tax-and-spending package, a Treasury Department official said.

The notices will make regulations out of the four pieces of guidance published late in 2025, Jim Wang, acting international tax counsel at Treasury, said Wednesday. He made his remarks during the 2026 DC Bar Tax Conference.

The pieces of guidance cover: the “pro-rata share” transition rule under Section 951 of the tax code, which details how US shareholders can calculate their share of their foreign affiliate’s income under a new method ...