CFC Pro Rata Share of Subpart F Income and Tested Income
Current understanding
To be populated as evidence accumulates.
Evidence log
- 2026-08-26 — Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss: IRS proposed rule would revise how U.S. shareholders of controlled foreign corporations calculate their pro rata share of Subpart F income and tested income or loss for current U.S. tax inclusion. (novelty: 2)
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Contributing findings
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss
26-aug-2026
novelty 2
per-area 2
introduces