Weil Tax BLOG - Feed https://tax.weil.com/contributor/isabela-cantarelli/ Views and developments from the Tax Department at Weil Tue, 14 Apr 2026 20:54:30 +0000 hourly 1 IRS Issues Final and Proposed Regulations Clarifying Section 892 Exemption for Foreign Government Investors https://tax.weil.com/latest-thinking/irs-issues-final-and-proposed-regulations-clarifying-section-892-exemption-for-foreign-government-investors/ Thu, 18 Dec 2025 17:28:44 +0000 Devon Bodoh Isabela Cantarelli https://tax.weil.com/?p=2595 On December 12, 2025, the Internal Revenue Service (“IRS”) released final regulations under Section 892 of the Internal Revenue Code (TD 10042), together with proposed regulations (REG-101952-24), addressing when a foreign government or their controlled entities is treated as engaged in commercial activity (and certain other matters relating to the application of Section 892). The

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