Weil Tax BLOG - Feed https://tax.weil.com/contributor/george-vallejo/ Views and developments from the Tax Department at Weil Fri, 23 Oct 2026 17:44:27 +0000 hourly 1 Proposed Treasury Regulations Address Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income https://tax.weil.com/insights/proposed-treasury-regulations-address-allocation-and-apportionment-of-deductions-to-foreign-source-section-951a-category-income-and-deduction-eligible-income/ Fri, 11 Sep 2026 14:37:16 +0000 Devon Bodoh George Vallejo Ricardo Fernandez https://tax.weil.com/?p=2694 On September 11, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117273-25) under Sections 904(b)(5) and 250(b)(3) addressing the allocation and apportionment of deductions to foreign source Section 951A category income for foreign tax credit limitation purposes and the computation of deduction eligible income (“DEI”).1 The Proposed Regulations

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]]> On September 11, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117273-25) under Sections 904(b)(5) and 250(b)(3) addressing the allocation and apportionment of deductions to foreign source Section 951A category income for foreign tax credit limitation purposes and the computation of deduction eligible income (“DEI”).1 The Proposed Regulations

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]]> Proposed Treasury Regulations Implement OBBBA Changes to CFC Pro Rata Share Rules for Subpart F Income, Tested Income, or Tested Loss https://tax.weil.com/insights/proposed-treasury-regulations-implement-obbba-changes-to-cfc-pro-rata-share-rules-for-subpart-f-income-tested-income-or-tested-loss/ Wed, 26 Aug 2026 20:30:17 +0000 Devon Bodoh Stephanie Galvis George Vallejo https://tax.weil.com/?p=2689 On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> Proposed Treasury Regulations Clarify Scope of Section 250 Exclusion for Certain Property Dispositions https://tax.weil.com/insights/proposed-treasury-regulations-clarify-scope-of-section-250-exclusion-for-certain-property-dispositions/ Fri, 21 Aug 2026 21:23:12 +0000 Devon Bodoh Zachary Torres George Vallejo https://tax.weil.com/?p=2684 On August 20, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117130-25) under Section 250 addressing the treatment of certain sales and other dispositions of property for purposes of determining foreign-derived deduction eligible income (“FDDEI”) (the “Proposed Regulations”).1 The Proposed Regulations clarify the scope of the exclusions from

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]]> On August 20, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117130-25) under Section 250 addressing the treatment of certain sales and other dispositions of property for purposes of determining foreign-derived deduction eligible income (“FDDEI”) (the “Proposed Regulations”).1 The Proposed Regulations clarify the scope of the exclusions from

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