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Final And Proposed Regulations Under Section 892—key Developments For Sovereign Investors
On December 12, 2025, the U.S. Treasury Department and the Internal Revenue Service issued final regulations under section 892 of the Internal Revenue Code of 1986, as amended relating to the U.S. federal income tax exemption available to foreign sovereigns, and certain international organizations in respect of certain types of investment income.
A&O Shearman