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  • Treasury, IRS issue Section 892 proposed regulations to provide . . .
    IR-2026-69, May 29, 2026 — The Department of the Treasury and the Internal Revenue Service today issued additional guidance addressing the applicability dates of recent proposed regulations under Section 892 of the Internal Revenue Code, which exempts foreign governments, including sovereign wealth funds, from tax on certain income derived
  • 26 U. S. Code § 892 - Income of foreign governments and of international . . .
    For purposes of this title, a foreign government shall be treated as a corporate resident of its country A foreign government shall be so treated for purposes of any income tax treaty obligation of the United States if such government grants equivalent treatment to the Government of the United States
  • Foreign governments and certain other foreign organizations
    U S investment income that is paid to a foreign government, even if exempt from tax under section 892, is subject to reporting on Form 1042-S, Foreign Person's U S Source Income Subject to Withholding
  • Final and proposed regulations: Income of non-U. S. governments and of . . .
    The final regulations (T D 10042) modify and clarify the rules under section 892 regarding the exemption from U S income tax for non-U S governments and their controlled entities
  • Breaking (film) - Wikipedia
    When the VA unexpectedly withholds his payment due to a disputed debt of $892 to a for-profit college, Easley is left homeless and increasingly desperate Determined to make his voice heard and to expose the system that failed him, Easley walks into a Wells Fargo bank branch in Marietta, Georgia
  • Income of Foreign Governments and of International Organizations
    Section 892 (a) (2) (B) provides that, for purposes of section 892 (a) (2) (A), a CCE is any entity engaged in commercial activities (whether within or outside the United States) and in which a foreign government holds (directly or indirectly) interests that meet specified thresholds
  • Treasury, IRS Issue Section 892 Proposed Regulations to Provide . . .
    On December 15, 2025, Treasury and the IRS issued proposed regulations under Section 892, clarifying when an acquisition of debt by a foreign government is commercial activity and when a foreign government has effective control of an entity engaged in commercial activities, in which cases the exemption does not apply
  • 892 - Wikipedia
    Year 892 (DCCCXCII) was a leap year starting on Saturday of the Julian calendar, the 892nd year of the Common Era (CE) and Anno Domini (AD) designations, the 892nd year of the 1st millennium, the 92nd year of the 9th century, and the 3rd year of the 890s decade
  • Treasury releases final and proposed regs on Section 892: PwC
    Treasury and the IRS on December 12, 2025, issued (1) final regulations and (2) proposed regulations under Section 892 on the US taxation of income earned by foreign governments and their controlled entities from investments in the United States
  • US Treasury Issues Final and Proposed Regulations Under Section 892 . . .
    The Proposed Regulations clarify that partnerships are not “controlled entities” for Section 892 purposes and that partnerships will not be treated as per se corporations, even if wholly owned by two controlled entities of a single foreign sovereign





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