Par. 3. Section 1.901-2 is amended by revising paragraph (f)(6) to read as follows:
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(f) * * *
(6) Allocation of foreign income taxes in connection with certain elections and status change events. For rules relating to the allocation of foreign income taxes in connection with elections made pursuant to section 336(e), see § 1.336-2(g)(3)(ii). For rules relating to the allocation of foreign income taxes in connection with elections made pursuant to section 338, see § 1.338-9(d). For rules relating to the allocation of foreign income taxes in connection with elections made pursuant to § 1.245A-5(e)(3)(i), see § 1.245A-5(e)(3)(i)(B) (applicable to taxable periods of foreign corporations beginning before December 31, 2025). For rules relating to the allocation of foreign income taxes in connection with an election pursuant to § 1.951-1(d)(2) or a status change event under § 1.951-1(d)(1), see § 1.951-1(d)(3).
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