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Treasury Regulations · 26 CFR

§ 1.892-4T. Commercial activities (temporary regulations).

Temporary regulation eCFR current as of October 15, 2026

Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

Regulation under 26 U.S.C. § 892

Cite as 26 CFR § 1.892-4T

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
June 27, 1988 by T.D. 8211
Last amended
December 15, 2025 by T.D. 10042
Issued under
26 U.S.C. § 892
Length
350 words · about 2 min to read
Defines
1 term
Cross-references
cites 0 Code sections and 2 regulations; cited by 5
(a) Purpose. For further guidance, see § 1.892-4(a).
(b) In general. For further guidance, see § 1.892-4(b).
(c) Activities that are not commercial—
(1) Investments—
(i) In general. For further guidance, see § 1.892-4(c)(1)(i).
(ii) Trading. For further guidance, see § 1.892-4(c)(2).
(iii) Banking, financing, etc. Investments (including loans) made by a banking, financing, or similar business constitute commercial activities, even if the income derived from such investments is not considered to be income effectively connected to the active conduct of a banking, financing, or similar business in the U.S. by reason of the application of § 1.864-4(c)(5).
(2) Cultural events. Performances and exhibitions within or outside the United States of amateur athletic events and events devoted to the promotion of the arts by cultural organizations are not commercial activities.
(3) Non-profit activities. Activities that are not customarily attributable to or carried on by private enterprise for profit are not commercial activities. The fact that in some instances Federal, State, or local governments of the United States also are engaged in the same or similar activity does not mean necessarily that it is a non-profit activity. For example, even though the United States Government may be engaged in the activity of operating a railroad, operating a railroad is not a non-profit activity.
(4) Governmental functions. Governmental functions are not commercial activities. The term “governmental functions” shall be determined under U.S. standards. In general, activities performed for the general public with respect to the common welfare or which relate to the administration of some phase of government will be considered governmental functions. For example, the operation of libraries, toll bridges, or local transportation services and activities substantially equivalent to the Federal Aviation Authority, Interstate Commerce Commission, or United States Postal Service will all be considered governmental functions for purposes of this section.
(5) Purchasing. The mere purchasing of goods for the use of a foreign government is not a commercial activity.

[T.D. 8211, 53 FR 24063, June 27, 1988, as amended by T.D. 10042, 90 FR 57916, Dec. 15, 2025]

Terms defined here

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Other regulations under § 892

Cross-references

Computed from the citations in the text of 26 CFR.

Regulations it cites

Cited by 5 other regulations

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

  1. Amended by T.D. 10042 (90 FR 57916)
  2. Issued by T.D. 8211 (53 FR 24063)

Where it sits in 26 CFR

  1. Subchapter A Income tax
  2. Part 1 Income taxes
  3. Miscellaneous provisions

Nearby sections