Proposed Regulations on Taxation of U.S. Income Earned by Foreign Governments

The recent surge in foreign government investing in the U.S. economy, particularly through Sovereign Wealth Funds, has prompted the Internal Revenue Services (“IRS”) to modify the existing Section 892 regulations regarding taxation of U.S. income earned by foreign governments. In a nutshell, Section 892 exempts foreign governments’ income from investing in U.S. stock, bonds and…

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