IRSFinal Rule

Entities Wholly Owned by Indian Tribal Governments

Finance & BankingOther

Summary

This IRS regulation clarifies the tax rules for businesses that are completely owned by Indian tribal governments. It helps tribal governments understand which of their business operations can get special tax benefits and how to properly report them to the federal government.

Key Points

  • 1Defines which business entities qualify as being 'wholly owned' by tribal governments and therefore eligible for certain tax exemptions
  • 2Applies to tribal enterprises and organizations that operate businesses on behalf of Native American tribes
  • 3Requires proper documentation and reporting procedures so the IRS can verify that businesses meet the ownership requirements
  • 4Protects tribal sovereign immunity—the legal authority of tribes to govern themselves—in tax matters
  • 5Affects tribal governments, tribal-owned businesses, and potentially Native American employees of these entities

Key Dates

Published

December 16, 2025

This summary is for informational purposes only. It may not capture all nuances of the regulation. Always refer to the official text for authoritative information.

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