The IRS is looking to rewrite the playbook on how it taxes foreign government investment funds operating in the United States, and some of the world's largest sovereign wealth funds might not love what they're reading.
IRS Proposes New Rules That Could Squeeze Sovereign Wealth Funds on US Deals
Get ImmunityBio Alerts
Weekly insights + SMS alerts
How the Tax Exemption Currently Works
Right now, Section 892 of the U.S. tax code gives foreign governments and entities they control—think sovereign wealth funds and certain public pension funds—a pass on U.S. taxes for investment activities. The catch? If the IRS decides what you're doing looks more like running a business than passive investing, you're on the hook for taxes.
The new proposal would broaden what the IRS considers commercial activity. That could hit sovereign wealth funds that lend money to companies or take direct equity positions in private firms.
Here's where it gets interesting: under the proposed rules, participating in a company's debt restructuring would count as commercial activity. That's true even if the sovereign wealth fund bought those bonds years earlier when everything looked fine and default risk was practically nonexistent.
Comments on the proposals are due by February 13.
The Big Picture on Sovereign Wealth Funds
Sovereign wealth funds are government-owned investment vehicles, typically funded by commodity revenues, foreign exchange reserves, or budget surpluses. They deploy capital into stocks, real estate, and infrastructure projects worldwide.
The stakes are considerable. In 2025, state-owned investors held $550 billion in private credit globally, according to Global SWF. Their direct U.S. private equity investments more than tripled to $73 billion, primarily through co-investments.
More News

Markets Rise as U.S. and Iran Hit Pause on Strikes; Big Tech Earnings and Fed Decision Loom

Trump Admin to Pump $1 Billion into this "Off-the-Radar" AI Stock

Oil Tumbles and Stocks Rise as Trump Gives Iran Diplomacy 'Some Space'

Iran Says It Won't Let the US Dictate the War's Pace, Strait of Hormuz Stays Closed

Trump’s Tariff Gambit Puts Canadian Oil in the Crosshairs—and U.S. Gas Prices on the Line

Your Download Link (Expiring)

Sen. John Kennedy Warns Trump's Saudi Nuclear Deal Sends Wrong Signal Amid Iran Tensions: 'The World Is on a Hair Trigger'

Apple's AI Strategy Is a High-Stakes Bet—and One Analyst Thinks It's Wrong
Get ImmunityBio Alerts
Real-time alerts on price moves, news, and trading opportunities.
Join 20,000+ investors. No spam, ever.
Featured Articles
View all news
Markets Rise as U.S. and Iran Hit Pause on Strikes; Big Tech Earnings and Fed Decision Loom

Trump Admin to Pump $1 Billion into this "Off-the-Radar" AI Stock (Ad)

Oil Tumbles and Stocks Rise as Trump Gives Iran Diplomacy 'Some Space'

Iran Says It Won't Let the US Dictate the War's Pace, Strait of Hormuz Stays Closed

Trump’s Tariff Gambit Puts Canadian Oil in the Crosshairs—and U.S. Gas Prices on the Line

Have you tried Elon Musk’s 70X AI agent? (Ad)

Sen. John Kennedy Warns Trump's Saudi Nuclear Deal Sends Wrong Signal Amid Iran Tensions: 'The World Is on a Hair Trigger'






