Treasury, IRS issue guidance on tax exemptions for foreign governments

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By Dave Kovaleski  |  June 2, 2026

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued guidance on the applicability dates of proposed regulations that exempt foreign governments from tax on certain income derived from passive U.S. investments. The additional guidance provides grandfathering protection and transitional relief to foreign governments investing in the United States. “Treasury and the IRS conducted thorough reviews of taxpayer and stakeholder comments on proposed technical U.S. t...

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