Federal Register #REG-117130-25

IRS Proposed Rulemaking on Excluded Property Sales Income Guidance

This opportunity involves a proposed rulemaking by the Internal Revenue Service (IRS) under the Treasury Department, focused on guidance for domestic corporations regarding excluded property sales income under section 250 of the Internal Revenue Code. - Government Buyer: - Department of the Treasury - Internal Revenue Service (IRS) - OEMs and Vendors Mentioned: - Rolls-Royce Deutschland Ltd & Co KG (referenced in an FAA airworthiness directive context, not as a procurement item) - Products/Services Requested: - No products or services are being requested; this is a regulatory guidance notice - Notable Requirements: - Clarifies treatment of income and gain from sale/disposition of intangible property and other depreciable, amortizable, or depletable assets - Guidance affects domestic corporations with foreign-derived deduction eligible income (FDDEI) - Defines scope of excluded property sales income, including treatment of copyrighted articles, software, and inventory - Outlines recordkeeping requirements and regulatory impacts - No procurement or acquisition activity is involved

Description

This document contains proposed regulations under section 250 of the Internal Revenue Code that provide guidance on certain income of a domestic corporation excluded in the determination of deduction eligible income. The income category includes income and gain from the sale or other disposition of intangible property and other property subject to depreciation, amortization, or depletion. The proposed regulations affect domestic corporations with foreign-derived deduction eligible income and clarify the treatment of such income for tax purposes. Comments on the proposed rule must be received by October 5, 2026.

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