IRS Proposes New Tax Rules for U.S. Companies With Foreign Income and Overseas Operations

The IRS and Treasury Department are proposing new rules for allocating deductions when certain U.S. companies calculate foreign tax credits and deductions connected to foreign-derived income. DK_STUDIO29/Shutterstock

U.S. companies doing business overseas could face updated rules for calculating important international tax deductions and foreign tax credits under a new proposal from the Internal Revenue Service and Treasury Department.

The proposed regulations, published September 11, are intended to implement international tax changes Congress enacted in the 2025 One, Big, Beautiful Bill Act.